🔥tomsComplaint

1.0 full caption

1.1 short caption

2.0 preamble

3.0 introduction

4.0 courtnapped!

5.0 preliminary allegations

6.0 a brief history of tom

7.0 the defendants

8.0 preliminary definitions (and stuff)

9.0 statement of facts and procedural history

9.1 defendant chester county pennsylvania et al.

9.2 defendant delaware county pennsylvania et al.

9.3 defendant berks county pennsylvania et al.

9.4 defendant lebanon county pennsylvania et al.

9.5 defendant washington district of columbia et al.

9.6 defendant state of new jersey et al.

9.7 defendant commonwealth of pennsylvania et al.

9.8 defendant united states et al.

10.0 legal claims

11.0 certification jury demand and signature

(DRAFT) PLAINTIFFS’ COMPLAINT

Thomas P. Connelly, Jr., JD, plaintiff, pro se in the above-captioned matter (“Plaintiff Connelly” or “Connelly”), in complaint against the defendants, and in support of the plaintiffs’ application for compensatory damages, punitive damages, and declaratory relief, says, upon information and belief and/or upon penalty of perjury, as follows:

1. Plaintiffs hereby incorporate by reference the ‘Google Docs’ version of the herein Complaint as Exhibit PC-0 (🔥tomsComplaint) (https://attorneytpc.pro/tomsComplaint), in its entirety, and requests that this Honorable Court take judicial notice of same.

2. Plaintiffs hereby incorporate by reference each and every document/thing filed in the following matters along with the parent spreadsheet itself as Exhibit PC-1 (☮️tomsList) (https://attorneytpc.pro/tomsList), in its entirety, and requests that this Honorable Court take judicial notice of same:

Kassel, D. v. Connelly, T., Civ. Action No. 2011-1215 (Delaware Pa. 2011);

Estate of Michael DiMeo Sr., et al. v. Kayati, Civ. Action No. L-2883-15 (Atlantic NJ 2014);

Kayati, J. v. D3K Associates, LLC, Civ. Action No. L-2884-15 (Atlantic NJ 2014);

Comm. v. Connelly, T., Crim. Action No. CP-06-CR-3185-2019 (Berks Pa. 2019);

Comm. v. Connelly, T., Crim. Action No. MJ-23302-CR-0141-2019 (Berks Pa. 2019);

Connelly, L. v. Connelly, T., Civ. Action No. 2020-2419-CU (Chester Pa. 2020);

Connelly, T. v. Connelly, L., et al., Civ. Action No. 20-15787 (Berks Pa. 2020);

Connelly, T. v. Connelly, L., et al., Civ. Action No. 20-16243 (Berks Pa. 2020);

Comm. v. Connelly, T., Crim. Action No. CP-15-CR-3020-2020 (Chester Pa. 2020);

Connelly v. Connelly, 2341 EDA 2020 (Pa. Cmmw. Ct. Oct. 15, 2021);

In re Connelly, T., Civ. Action No. 21-10334-pmm (Bankr. E.D. Pa. 2021);

Comm. v. Connelly, T., Pet., Civ. Action No. 68 MM 2021 (Pa. 2021);

Connelly, L. v. Connelly, T., Civ. Action No. 69 MM 2021 (Pa. 2021);

Kassel, D. v. Connelly, T., Jr., Pet., Civ. Action No. 70 MM 2021 (Pa. 2021);

Connelly v. Chesco CCP Judges, et al., Civ. Action No. 72 MM 2021 (Pa. 2021);

Connelly, T., Pet. v. P.J. Delaware Co., et al., Civ. Action No. 87 MM 2021 (Pa. 2021);

Connelly v. Neumann, et al., Civ. Action No. 21-11881 (Berks Pa. 2021);

Connelly, et al. v. Connelly, et al., Civ. Action No. 5:21-cv-3981 (E.D. Pa. 2021);

Connelly v. UPS, Inc., Civ. Action No. 21-15314 (Berks Pa. 2021);

Connelly v. Ashley Furniture Industries, Civ. Action No.22-1487 (Berks Pa. 2022);

Connelly v. CIGNA Corp., Civ. Action No. 22-1475 (Berks Pa. 2022);

Connelly v. TTEC Holdings, Civ. Action No. 22-1477 (Berks Pa. 2022);

Connelly, et al. v. Brooks, et al., Civ. Action No. 22-2612 (Berks Pa. 2022);

Connelly v. SIR, Civ. Action No. 895 MDA 2022 (Pa. Super. 2022);

Comm. v. Connelly, T., Crim. Action No. MJ-23203-CR-0102-2022 (Berks Pa. 2022);

Comm. v. Connelly, T., Crim. Action No. MJ-23303-CR-0045-2022 (Berks Pa. 2022);

Brooks, E., et al. v. Petsch, S., et al., Civ. Action No. 22-2619 (Berks Pa. 2022);

Connelly, et al. v. Green, et al., Civ. Action No. 5:22-cv-1163 (E.D. Pa. 2022);

Comm. v. Connelly, T., Crim. Action No. CP-06-CR-1008-2022 (Berks Pa. 2022);

Comm. v. Connelly, T., Crim. Action No. CP-06-CR-1551-2022 (Berks Pa. 2022);

Comm. v. Connelly, T., Crim. Action No. 1400 MDA 2022 (Pa. Super. 2022);

Comm. v. Connelly, T., Crim. Action No. 1406 MDA 2022 (Pa. Super. 2022);

Connelly, T., et al. v. Connelly, L., et al., Civ. Action No. 2022-5726-TT (Chester Pa. 2022);

Comm. v. Connelly, T., Crim. Action No. MJ-23203-CR-0005-2023 (Berks Pa. 2023);

Comm. v. Connelly, T., Crim. Action No. CP-06-CR-0224-2023 (Berks Pa. 2023);

Estate of Joselyn C. Kayati, No. CP-38-23 (Camden NJ 2023);

Kayati, J. v. Kayati-Brown-Tabaei, C., Civ. Action No. L-001176-23 (Camden NJ 2023);

Root v. Connelly, Civ. Action No. 2023-1319 (Lebanon Pa. 2023);

Connelly v. Root, et al., Civ. Action No. 2023-1382 (Lebanon Pa. 2023);

In re Connelly (US v. Connelly), Crim. Action No. 2023 FUG 008879 (Dec. 2, 2023);

Office of Disciplinary Counsel v. Connelly, Civ. Action No. 2936-0003 (Pa. 2024);

Connelly v. Warden, BCJ, et al., Civ. Action No. 5:24-cv-0145 (E.D. Pa. 2024);

Connelly, T. v. Connelly, L., Civ. Action No. 619 EDA 2024 (Pa. Super. 2024);

Connelly v. Warden, BCJ, et al., Civ. Action No. 24-2099 (3rd. Cir. 2024);

Connelly v. House, et al., Civ. Action No. C-07-CV-24-423 (Cecil Md. 2024);

Connelly, T., v. Root, H., Civ. Action No. 1235 MDA 2024 (Pa. Super. 2024).

Exhibit PC-1 (☮️tomsList) (https://attorneytpc.pro/tomsList).

3. Plaintiffs hereby incorporate by reference Plaintiff Connelly’s selected consolidated docket reports as Exhibit PC-2 (📘tomsDockets) (https://attorneytpc.pro/tomsDockets).

4. Plaintiffs hereby incorporate by reference each and every document and thing contained within Plaintiff Connelly’s relevant evidence folder as Exhibit PC-3 (💾tomsEvidence) (https://attorneytpc.pro/tomsEvidence).

5. Plaintiffs also specifically incorporate all the documents and things hyperlinked herein and the within exhibits, irrespective of their status as an exhibit. For example, if the Court clicks on Plaintiff Connelly’s plaintiff children’s names, It will be referred to photographs of those children (10,283 of them at the time of this writing).

INTRODUCTION

1. In May of 2019, Plaintiff Connelly was attacked without provocation by three patrons of Defendant Little Oley Tavern, Boyertown, Berks County, Pennsylvania, and a fight ensued.

2. Three local police departments responded, and Plaintiff Connelly, who is trained in the martial art of Aikido, defended himself until someone (more likely than not a police officer), stomped on his right ankle while he was prone on the floor of the tavern, breaking the ankle in three places and permanently damaging it.

3. Plaintiff Connelly lost consciousness, but came-to while the arresting officers dragged him out to their patrol vehicle on his displaced fracture, probably from the pain (Connelly was training for an ironman triathlon at the time his ankle was broken, but now uses a brace and sometimes a cane due to the permanent, irreparable damage to the cartilage of his tibia).

4. Defendant Police Officer Ryan M. Foltz took Plaintiff Connelly to Reading Hospital (Defendant Tower Health) where the displaced fracture was set while Connelly was handcuffed to the gurney, and then to the Berks County Jail (“BCJ”) for the first of ultimately four visits (totalling over six months–all pretrial), where he first met Defendant BCJ Corrections Officer Cunningham in the intake unit.

5. Cunningham asked Plaintiff Connelly what Connelly now understands was Cunningham’s ‘standard’ screening question for suicidal ideation, something like ‘how do you feel about your future?’ Connelly answered ‘well not great, I’m in jail…’ or something to that effect.

6. Cunningham was not amused, and placed Connelly in the medical ‘hole’ on 24-7 suicide watch, meaning that Connelly’s clothes were taken, he was given a ‘turtle suit’ and ‘turtle sheet’ (they’re green in color) and was observed at all times by a female corrections officer (Plaintiff Connelly believes this was intentional).

7. Plaintiff Connelly would later suffer post traumatic stress disorder (“PTSD”) symptoms, to wit, flashbacks and nightmares from this and subsequent times in the ‘hole’ (40 days and 40 nights). See, e.g., Exhibit PC-2 (📘tomsDockets), Connelly v. Warden, BCJ, et al., Civil Action No. 5:24-cv-145 (E.D. Pa. Jun. 10, 2024), ECF-2, incorporated and attached as Exhibit PC-4  (petition  for writ of habeas corpus), and ECF-6 incorporated and attached as Exhibit PC-5 (amended petition for writ of habeas corpus against warden, berks county jail).

8. Cunningham appears to derive sexual pleasure from his sadism, and his perversions are well-known to the inmates at the BCJ. See, e.g., Patterson v. Quigley, Civil Action No. 16-1604 (E.D. Pa. Mar. 30, 2018).

9. Plaintiff Connelly did not understand why he was on suicide watch or indeed why he was even at medical, because the medical staff, Defendant PrimeCare Medical, Inc., failed to treat him in any way, not even with a set of crutches, but after further experience with Cunningham, came to understand that it was punishment for mouthing-off.

10. In order to cover up the assault/battery/excessive force (and some other criminal activity that is best left for Plaintiff Connelly’s deposition due to its sensitive nature), and to suppress Plaintiff Connelly’s ability to seek legal redress for same, the police officers involved in the ‘bar fight’ incident colluded and conspired with defendant attorneys John T. Adams, Kathryn Lehman, Colin Boyer and Kevin Howard to ‘throw the book’ at Plaintiff Connelly, who at the time was living in Woodbury, New Jersey, but overnighting in a Boyertown, Berks County, Pennsylvania room during the work week, while acting as the sole support for his then-wife, Defendant Larissa C. Connelly, who refused to work, and his beloved daughter, Plaintiff OWC, working at Penske Corporation on location in Reading and GlaxoSmithKline in a hybrid capacity, in two full-time roles as a digital analytics project manager.

11. Plaintiff Connelly had given up practicing law in 2017 because he had become disgusted with his ‘colleagues’ at bench and bar. For example, one judge of Defendant, State of New Jersey refused to give Connelly a continuance of a case near New York City while Connelly was hospitalized at the University of Pennsylvania in Philadelphia recovering from emergency brain surgery. See also, e.g., Exhibit PC-6 (2023-11-29 (non) appearance before mary t. johnson JCCP), and infra, for abjectly disgusting conduct by attorneys and judges.

12. Since the ‘bar fight’ incident, Plaintiff Connelly has been charged by Defendant, Commonwealth of Pennsylvania with approximately twenty crimes, including multiple felonies, in five separate cases: four authorized and maliciously prosecuted despite notice by Defendant Berks County District Attorney John T. Adams, and one authorized and maliciously prosecuted despite notice by Defendant Deborah S. Ryan JCCP, who was, at all relevant times, the District Attorney of Chester County, Pa., but is now a judge of the Court of Common Pleas of Defendant Commonwealth of Pennsylvania.

13. These frivolous, meritless and malicious prosecutions of Plaintiff Connelly ultimately proved to be just that.

14. Plaintiff Connelly represented himself in the Chester County, Pa. matter, and was acquitted at trial solely because the powers that ‘were’ (primarily Defendant Jacqueline C. Cody, JCCP and Ryan) knew that the process was so intentionally and irreparably f[***]ed that no conviction would survive an appeal, and moreover that these criminals would be exposed thereby. See, e.g., Exhibit PC-7 (2021-07-21 gmail: connelly, t., pet. v. hon. cody, et al. pa. 72 MM 2021 your client deborah ryan, esq.), and infra.

15. In the Berks County matters, Plaintiff Connelly pled to three summary harassment counts, one guilty and two nolo contendere. Defendants Commonwealth of Pennsylvania and Adams, et al. even managed to fuck screw that up. E.g., Exhibit PC-8 (2022-09-09 gmail: re comm. v. connelly).

16. The guilty plea offer (Connelly’s request for a nolo plea was refused) was in exchange for Plaintiff Connelly’s law license in Pennsylvania. See, e.g., Exhibit PC-2 (📘tomsDockets), Connelly v. Warden, BCJ, et al., Civil Action No. 24-2099 (3rd. Cir. 2024), ECF-15, incorporated and attached as Exhibit PC-9 (motion filed by attorney thomas p. connelly, jr., esq. to withdraw as counsel or for clarification); Office of Disciplinary Counsel v. Connelly, No. 2936-3 (Pa. Feb. 29, 2024).

17. Plaintiff Connelly filed notices of appeal of all three judgments of conviction, but was prevented from litigating them to completion by the criminal, tortious, negligent, grossly negligent, and otherwise unlawful conduct/inaction of the defendants herein.

18. Nevertheless, once these ‘tickets’ are expunged, Plaintiff Connelly will have no criminal record whatsoever. 

19. The threads common to the frivolous charges brought against Plaintiff Connelly and/or their natural consequences, see, e.g., Palsgraf v. Long Island R.R. Co., 248 N.Y. 339, 162 N.E. 99 (N.Y. 1928), were/are: (1) criminal, tortious and grossly negligent conduct by municipal police, e.g., supra and infra, and Defendant Pennsylvania State Police, primarily Defendant Troopers Brian J. McCabe, James Green, and Matthew Truscott; (2) criminal, tortious, negligent and/or grossly negligent conduct and abuse of prosecutorial discretion by Defendants Adams, Ryan, and their defendant subordinates; (3) criminal, tortious, negligent and/or grossly negligent conduct by public and private-party defendants, including but not limited to Defendants Berks County Sheriff Eric J. Weaknecht, Meredith H. Wooters, Esq., Firefly Legal, Inc., Howard T. Root and his defendant attorneys, Defendant Cleona Borough’s Police Department, Veterans on the Rise, the Washington DC Metropolitan Police, Meeting Ground d/b/a the “Cecil County Men’s Shelter”, Elkton, Maryland’s Police Department and the United States of America (via defendant ‘social workers’ Craig Cook and Jennifer L. Reed), which conduct rendered Plaintiff Connelly involuntarily homeless; (4) criminal, tortious, and grossly negligent conduct by public and private-party defendants that rendered Plaintiff Connelly involuntarily jobless, including but not limited to unlawful discrimination in hiring by Defendants Ashley Furniture Industries, Cigna Corporation, Starbucks Corporation, TTEC Holdings and United Parcel Service, Inc.; (5) an ongoing criminal conspiracy to alienate Plaintiff Connelly from his beloved plaintiff children, and the trafficking in those children by Defendants Larissa C. Connelly and Dora L. Kassel, their family members, attorneys, and their judicial and executive branch enablers, most of those enablers being employees, officers and/or agents of the criminal enterprise that is Defendant Commonwealth of Pennsylvania, and led by its child-abusing criminal kingpin, Defendant Governor Josh D. Shapiro (dating back to his time as Attorney General of Pennsylvania), or of the defendant Pennsylvania Counties of Chester and Delaware; and (6) criminal, tortious, negligent and/or grossly negligent conduct by each and every one of the judges that Plaintiff Connelly has encountered in the state and federal systems. See, e.g., Exhibit PC-6 (2023-11-29 (non) appearance before Mary T. Johnson JCCP) and infra.

20. The seventh, final, and most central theme to Plaintiff Connelly’s experience of ‘justice’ in this country over the past four years has been his prosecution (and persecution), civilly and criminally, for judicially- and constitutionally-privileged statements (i.e., Plaintiff Connelly’s: words, speech[es], expression[s], writing[s], conversation[s], dialogue[s], discussion[s], articulation[s], communication[s], diction[s], elocution[s], enunciation[s], idiom[s], intercourse[s], jargon[s], lingo[s], locution[s], palaver[s], parlance[s], prattle[s], pronunciation[s], prose[is a mass noun, which means it doesn't have a plural form], statement[s], spiel[s], tongue[s], utterance[s], verbalization[s], vernacular[s], vocalization[s], double-talk[s], expression[s], oral communication[s], vocal expression[s]) all made in the course of litigating his children’s custody and related matters. See, e.g., Office of Disciplinary Counsel v. Connelly, No. 2936-3 (Pa. Feb. 29, 2024).

21. As a direct and proximate result of the criminal, tortious, negligent, grossly negligent, and/or otherwise unlawful conduct/inaction of the defendants herein, he has had no contact with his beloved children, Plaintiffs Thomas Patrick Connelly, III, EMC and OWC for almost five years.

22. After Plaintiff Connelly’s pleas for help from government officials went unanswered, see, e.g., Exhibit PC-10 (2021-02-01 letter from connelly to AOPC) and PC-11 (2022-01-06 letter to josh shapiro copy to US attorney), he began diligently asserting his claims in the jurisdictions and venues appropriate to them, but has been stopped cold at every turn by official corruption, often in the person of those same officials from whom he sought help. See, e.g., Office of Disciplinary Counsel v. Connelly, No. 2936-3 (Pa. Feb. 29, 2024).

23. Upon being indecently assaulted by Defendant Howard T. Root, and unlawfully actually and/or constructively evicted by way of an illegal conspiracy among and between Root, Defendant Cleona Borough’s Police Department, chiefly its chief, Defendant Jeffrey J. Farneski, and Root’s defendant attorneys, e.g., Defendant Richard Raiders, Esq., Connelly filed an action in Lebanon County, Pennsylvania. See, e.g., Exhibit PC-12 (2023-10-11 gmail: criminal charges against farneski); Exhibit PC-13 (2024-08-06 full connelly mailing packet); Exhibit PC-2 (📘tomsDockets), Connelly v. Warden, BCJ, et al., Civil Action No. 5:24-cv-145 (E.D. Pa. Jun. 10, 2024), ECF-5, incorporated and attached as Exhibit PC-14 (2024-02-01 motion to appoint counsel/proceed IFP). That action, Connelly v. Root, et al., Civ. Action No. 2023-1382 (Lebanon Pa. 2023), was improperly terminated and then improperly dismissed per curiam by the corrupt Pennsylvania Superior Court. See Connelly, T., v. Root, H., Civ. Action No. 1235 MDA 2024 (Pa. Super. 2024).

24. Upon being kidnapped and unlawfully incarcerated by Defendants Commonwealth of Pennsylvania, Berks County, Pa., United States of America, Georgetown University and others on December 2, 2023, Plaintiff Connelly filed a petition for a writ of habeas corpus in the United States District Court for the Eastern District of Pennsylvania, Exhibit PC-2 (📘tomsDockets), Connelly v. Warden, BCJ, et al., Civil Action No. 5:24-cv-145 (E.D. Pa. Jun. 10, 2024), and pending his guilty plea in Comm. v. Connelly, T., Crim. Action No. CP-06-CR-0224-2023 (Berks Pa. 2023), moved to amend his pleadings in the federal action in order to assert in that action the claims he asserts herein. See, e.g., Exhibit PC-5 (amended petition for writ of habeas corpus against warden, berks county jail).

25. That application was improperly denied, Exhibit PC-2 (📘tomsDockets), Connelly v. Warden, BCJ, et al., Civil Action No. 5:24-cv-145 (E.D. Pa. Jun. 10, 2024), ECF-15, incorporated and attached as Exhibit PC-15 (Order Denying Application to Amend Pleadings), and the action was improperly dismissed, Exhibit PC-2 (📘tomsDockets), Connelly v. Warden, BCJ, et al., Civil Action No. 5:24-cv-145 (E.D. Pa. Jun. 10, 2024), ECF-18, incorporated and attached as Exhibit PC-16 (Order Adopting Recommendations and Dismissing Action as Moot), by Defendants Elizabeth T. Hey, USMJ and Karen S. Marston, USDJ, who also improperly joined Defendant Berks County Office of the District Attorney, Exhibit PC-2 (📘tomsDockets), Connelly v. Warden, BCJ, et al., Civil Action No. 5:24-cv-145 (E.D. Pa. Jun. 10, 2024), ECF-10, incorporated and attached as Exhibit PC-17 (Order Joining District Attorney of Berks County as a Party), which office was neither a proper legal entity (it is a Berks County agency) nor an interested party, and failed to join the proper, necessary, and interested parties, Defendants Commonwealth of Pennsylvania, Berks County, and United States. See, e.g., Exhibit PC-2 (📘tomsDockets), Connelly v. Warden, BCJ, et al., Civil Action No. 24-2099 (3rd. Cir. 2024), ECF-11, incorporated and attached as Exhibit PC-18 (Motion filed by Appellant Thomas P. Connelly, Jr. for Certificate of Appealability and to Join the United States as a Party).

26. The foregoing constituted multiple violations of 18 U.S.C. § 1346 (honest services fraud) (18 U.S.C. § 1346 defines the term “scheme or artifice to defraud,” as used in the general statutes prohibiting use of the mails or wires to commit fraud, to include a scheme or artifice to deprive another of the intangible right of honest services), and multiple predicate acts under 18 U.S.C. §§ 1961-68 (RICO).

27. The matter was dismissed by defendants, cowards and political hacks, Third Circuit Court of Appeals in a clear effort to protect its fellow criminals at the bench Marston and Hey. See Exhibit PC-2 (📘tomsDockets), Connelly v. Warden, BCJ, et al., Civil Action No. 24-2099 (3rd. Cir. 2024), ECF-26, incorporated and attached as Exhibit PC-19 (2024-10-22 Order Denying Petition for Rehearing en Banc).

28. As a consequence of the aforesaid actionable conduct and conduct to be more particularly described below, Plaintiff Connelly was rendered homeless and indigent. See, e.g., Exhibit PC-*** (2024-08-21 application for IFP status). He resided at the Cecil County Men’s Shelter, Maryland, until he was unlawfully evicted on August 2, 2024, and then at Defendants VAMC Coatesville at Building 8, until he was unlawfully evicted/discharged on or about October 21, 2024, the day he was notified by the Bucks County Coroner that his Father had passed. Both incidents caused a severe aggravation of Plaintiff Connelly’s PTSD, and emotional distress that expressed itself in physical manifestations of injury.

29. That unlawful eviction followed an almost identical unlawful eviction from Defendant Veterans on the Rise’s shelter in Washington, DC on November 28, 2023, e.g., Exhibits PC-*** (2023-11-28 VOTR 05:53) and PC-*** (2023-11-28 1050 VOTR), an assault, battery, and unlawful imprisonment/restraint by Defendant Georgetown University on December 1, 2023, e.g., Exhibits PC-*** (#hoyaSuxa origins), PC-*** (#hoyaSuxa) and PC-*** (2023-12-01 GU fraudulent bar notice), Plaintiff Connelly’s alma mater, while Connelly was protesting Defendant Starbucks’ anti-union conduct, and Plaintiff Connelly’s aforesaid subsequent kidnapping by agents of Defendants Commonwealth of Pennsylvania, County of Berks, United States (via Defendant U.S. Marshals), and others, the specifics of which are more particularly described in Exhibit PC-5 (amended petition for writ of habeas corpus against warden, berks county jail). 

30. Throughout the almost five years of alienation from his plaintiff children, Plaintiff Connelly has been able and willing to work, but has been denied employment at every turn due to the discriminatory hiring practices of Defendants Ashley Furniture, Cigna, TTEC, UPS, and Starbucks Corporation on the basis of his race, color, religion, sex, national origin, disability, and/or age (or the perception of same), and/or the defendants’ failure to follow EEOC guidelines for evaluating pending criminal charges (arrest records). Plaintiff Connelly was denied employment over and over again due to the mere pendency of the aforesaid frivolous criminal charges.  See, e.g., Exhibit PC-*** (2024-07-11 letter to EEOC supplemental); Exhibit PC-*** (2021-06-30 EEOC complaints all). 

31. Defendant, United States, also a criminal enterprise under RICO, not only participated in the kidnapping and the unlawful eviction of Plaintiff Connelly from Defendant VOTR, negligently failed to intervene, despite notice, in the trafficking of Plaintiff Connelly’s children, but has also been grossly and medically-professionally negligent, through its agents, including but not limited to Defendant Secretary Denis Richard McDonough in Plaintiff Connelly’s medical treatment. E.g., Exhibit PC-*** (mhv_CONNELLY_20240820_1906_redacted). 

32. That negligent/grossly negligent treatment by government actors began while Plaintiff Connelly was an active duty United States Navy service member, when naval flight surgeons failed to diagnose hydrocephalus in Plaintiff Connelly due to their refusal to refer Connelly for an MRI upon his report of headaches (Connelly was referred to psychology, who told him that his problem was medical–which Connelly knew, after having graduated at the top ten percent of his primary flight training class despite the headaches and diarrhea). 

33. Although Plaintiff Connelly’s most recent medical treatment at VAMC Coatesville, has been (finally) generally excellent, even that experience has been marred by a pattern of conduct whereby certain ‘social workers’ and nurses behave more like police or prison guards than medical professionals, thereby aggravating rather than treating Plaintiff Connelly’s PTSD/TBI, for example:

In the late evening of August 8, 2024 or the early morning of August 9, 2024, [Plaintiff Connelly] was subjected to an illegal 'strip search' upon [his] voluntary admission to Unit 59A (acute psychiatry) by Bonnie C. and Christa G. These female nurses would not admit [him] into the Unit for treatment until [he] completely exposed [him]self. [Connelly] requested that a male conduct the search, but was told there was none available. [Connelly] hadn't slept for at least 24 hours prior to the event, so [he] was exhausted. [Plaintiff Connelly] was also very hungry, so after waiting for some time for a male nurse, [Connelly] finally relented and consented to the search. This event further triggered [Connelly’s] chronic, complex PTSD, for which, ironically, [he] was seeking treatment. [Plaintiff Connelly] reported the incident to [his] treatment team at 59A, and to Shawn Rogan, MA, Patient Advocate (shawn.rogan@va.gov). [Plaintiff Connelly] had previously filed a lawsuit against the United States in the Cecil County, Maryland Circuit Court. See https://bit.ly/3ALUtIk. [Connelly is] now drafting an amended complaint to add the aforementioned nurses as defendants, and claims against them for conspiracy to violate [his] civil rights and medical professional negligence. [He] can be reached at occidentalbuddhist@gmail.com or thomaspatrickconnellyjr@gmail.com. Thank you for your kind attention to this matter. /s/ Thomas P. Connelly, Jr., JD 08-24-2024.

Exhibit PC-*** (2024-08-24 joint commission complaint).

34. It appears that the powers that ‘be’ will only be moved toward right and proper action at the point of a sword. This is that sword. Plaintiff Connelly will recover his plaintiff children from this corrupt and broken system, and bring justice to those responsible.

COURTNAPPED!

1. On March 5, 2020,  while Plaintiff Connelly was still recovering from his ankle fracture and participating in Berks County’s Accelerated Rehabilitative Disposition (“ARD”) Program for the ‘bar fight’ incident, Plaintiff Connelly’s then-wife Defendant Larissa Connelly, through her then-counsel, Defendant Julie M. Potts, filed a complaint for primary physical custody of the parties' child, Plaintiff OWC, then four years old.

2. Defendant Larissa Connelly’s complaint "did not include any factual assertions,” Connelly v. Connelly, 2341 EDA 2020 (Pa. Cmmw. Ct. Oct. 15, 2021), only legal conclusions. 

3. Thereafter, not having any factual basis for disparaging Plaintiff Connelly in his paternal role, Defendants Larissa Connelly and Potts conspired and colluded with corrupt Chester County hearing officers, Defendants Tracy L. Christman and Richard E. Lombardi, both socially connected to Potts on Facebook, e.g., EXHIBIT PC-*** (2020-12-26 FB potts↔christman) and EXHIBIT PC-*** (2020-12-26 FB lombardi↔potts) and otherwise, and Gregory J. Marshall, and Defendants McCabe, Ryan, and others, to manufacture one, and thereby to illegally and unfairly prejudice Plaintiff Connelly in his plaintiff children’s custody matters and to traffic in his minor plaintiff children in violation of Pennsylvania’s Act 105 of 2014, Act of Jul. 2, 2014, P.L. 945, No. 105 Cl. 18, 18 Pa. C.S.A. § 3011, et seq. and 18 Pa. C.S.A. § 3051, et seq. (“Human Trafficking”) and the Racketeer Influenced and Corrupt Organizations Act, 18 U.S.C. §§ 1961-68 (“RICO”). See, e.g., EXHIBIT PC-*** (2022-03-17 emergent petition for custody).

4. The objective of the conspiracy was to alienate Plaintiff Connelly from his plaintiff children and to injure Plaintiff Connelly emotionally and financially, thereby enabling the trafficking in Plaintiff Connelly’s plaintiff children, and the means were the filing and prosecution of multiple frivolous harassment and related charges against Plaintiff Connelly, and the solicitation of two fraudulent, void, and illegal custody orders ‘rubber-stamped’ by Defendant Judges Katherine BL Platt and Analisa Sondergaard though devoid of findings of fact and conclusions of law, all in violation of  Plaintiff Connelly's rights to due process and equal protection of the law, his moral right to access to his children, and the children’s moral right to the love and affection of their Father. See, e.g., Ashford v. Ashford, 395 Pa. Super. 125, 132 (Pa. Super. Ct. 1990) (“In no case is the de novo procedure to be simply a review for error or a rubber stamp approval of the recommendation of the hearing officer.”) (emphasis in original); accord  EXHIBIT PC-*** (2021-10-30 answer to application for panel reconsideration-reargument).

5. The filing of the frivolous harassment charges caused Plaintiff Connelly to lose his $100,000.00 per annum position working for Express Scripts, an online pharmacy, and in fact prevented him from obtaining any W-2 employment at all during the pendency of the multiple frivolous criminal prosecutions brought against him in Chester and Berks Counties due to the discriminatory hiring practices of the defendant employers herein. See, e.g., Exhibit PC-*** (2021-06-30 EEOC complaints all). 

6. The two custody orders, entered illegally and without a hearing or opinion by Defendants Platt and Sondergaard as 'final orders' in July and September, 2020, prevented Plaintiff Connelly from seeing his daughter, Plaintiff OWC, and, due to Defendants Larissa Connelly, Julie M. Potts' and others’ coordination with Plaintiff Connelly's ex-wife, Defendant Dora L. Kassel and her attorneys and other co-conspirators, also his two children from his relationship with Dora Kassel, Plaintiffs Thomas P. Connelly, III and EMC, for four years, seriously and irreparably harming and prejudicing Plaintiff Connelly and each of his three plaintiff children thereby.

7. By and through the criminal, tortious, negligent and/or grossly negligent conduct of Defendants Connelly and Kassel and their defendant aiders, abettors and co-conspirators, Plaintiff Connelly has been unlawfully deprived of an opportunity to bond with his children, and the Kassel Defendants and Defendant Larissa Connelly have used that stolen time to poison his children against him. This was/is purely and simply, child abuse. See Ashish Joshi, Cases of Parental Alienation in Pennsylvania Courts, The Pennsylvania Lawyer, March/April 2021, at 46, EXHIBIT PC-*** (Cases of Parental Alienation in Pennsylvania Courts).

8. Furthermore, by way of filing and maintaining child support claims based on the fraudulently obtained, illegal and void orders, Defendants Larissa Connelly, Potts, and Connelly’s subsequent counsel Defendant Attorney Craig B. Huffman, and others, have engaged in the human trafficking of OWC in violation of 18 Pa. C.S.A. § 3011 et seq.  E.g., EXHIBIT PC-*** (2021-10-30 answer to application for panel reconsideration-reargument).

9. With regard to Plaintiffs Thomas P. Connelly, III and EMC, Defendants Dora and Scott Kassel and their attorneys and judicial enablers have similarly engaged in human trafficking. In their case, however, there was never any sort of judicial order even ostensibly justifying their abuse of Plaintiff Connelly’s children.

10. This did not stop Defendant Commonwealth of Pennsylvania's criminal and constitutionally illegitimate Department of Human Services and its subservient and equally illegitimate domestic relations sections of Pennsylvania’s courts of common pleas (all executive branch entities) from freezing/levying Plaintiff Connelly’s financial accounts, and even his life insurance policy, to the point where Connelly could not pay for fuel to attend his custody/support hearings in Delaware and Chester Counties, Pennsylvania.

11. Early in 2019, prior to Plaintiff Connelly and Defendant Larissa Connelly’s separation later that year, Plaintiff Connelly was living in the Reading, Pennsylvania area during the work week, as his then onsite ‘C2C’ position with Penske through his agency Enactum, LLC required an in-office presence, and the commute from the family’s home in Woodbury, New Jersey to Reading was two and one-half hours each way.

12. Defendant Larissa Connelly, then an unemployed hairdresser, had refused to work, so Plaintiff Connelly was the sole provider to the family. In fact, Plaintiff Connelly paid for Defendant Larissa Connelly’s attendance at community college.

13. Plaintiff Connelly at that time began to read OWC to sleep, every evening, to maintain his relationship with her while he was away. This became Plaintiff Connelly’s ‘lifeline’ to his daughter and was deeply fulfilling to both him and OWC. This reading time continued after Plaintiff Thomas Connelly and Defendant Larissa Connelly’s separation in August 2019. See, e.g., Exhibit PC-*** (❤️4myKids).

14. Defendant Larissa Connelly moved in with her parents, Defendants Wayne and Janet Prewitt, and her brother, Defendant Defendant Arvil Prewitt, an unemployed forty-something with a gun collection, on a seven-acre compound in Oxford, Chester County, Pennsylvania.

15. After the parties’ separation, their customary division of parenting time was as follows: Plaintiff Connelly had minor Plaintiff OWC, every weekend at his home in Reading, Berks County (where he also welcomed his plaintiff children from his first marriage, Plaintiffs Thomas P. Connelly, III and EMC), from Friday evening until Sunday evening, and Defendant Larissa Connelly had her at all other times.

16. Plaintiff Connelly and Defendant Larissa Connelly had agreed that they would divorce amicably, that Plaintiff Connelly, who is legally trained, would handle the paperwork, and that they would not make any claims against one-another.

17. In reasonable reliance on Defendant Larissa Connelly’s promise, Plaintiff Connelly shared one-half of the proceeds of the sale of the parties’ home at 58 Laurel St Woodbury NJ 08096, the deed to which was in his name only.

18. Connelly broke her promise in March 2020, hiring hack attorney Defendant Julie M. Potts, a former Assistant District Attorney of Chester County (which she touted on her now defunct firm’s website), to maliciously prosecute, annoy, harass, and vex Plaintiff Connelly.

19. Plaintiff Connelly and Defendant Dora L. Kassel VMD, Connelly’s first wife, who is now remarried to a Villanova chemistry professor, Defendant Scott Kassel, have two children together. They are Plaintiff Thomas P. Connelly, III, age eighteen and minor Plaintiff EMC, age sixteen.

20. Plaintiff Connelly and Defendant Kassel separated in 2010 with the divorce having been finalized in 2011.

21. At the time of the entry of the divorce decree in 2011, Defendant Dora Kassel represented through her then-attorney, David I. Dubin Esquire, to Plaintiff Connelly that if Plaintiff Connelly agreed to relinquish the marital home to Defendant Kassel and terminate his spousal support claims against her, Defendant Kassel, in return, would not seek child or spousal support, ever. Plaintiff Connelly accepted this offer and a binding contract arose.

22. From the time of the parties’ separation, Plaintiffs Thomas P. Connelly, III, and EMC visited Plaintiff Connelly every weekend, with adjustments made as necessary to accommodate the parties’ and children’s schedules.

23. This arrangement served Defendant Dora Kassel very well, as she in its early days needed to perform overnight duty as a junior veterinarian (which she scheduled for Plaintiff Connelly’s overnight visitation periods) and functioned without complaint from either parent about the parenting ability or moral character of the other for more than ten years.

24. That was true even though in 2014 or 2015, Defendant Dora Kassel (then “Dora L. Connelly”) was charged with Driving While Intoxicated (DWI) and was admitted into the Accelerative Rehabilitation Disposition (ARD) program. 

25. Although Plaintiff Connelly independently became aware of the charges when his second wife, Defendant Larissa Connelly ‘googled’ ‘Dora Connelly’, he understood that his minor children were not in the vehicle at the time and trusted that there was therefore little danger to them posed by Defendant Kassel’s unfortunate choice to drive drunk. The risk to Defendant Delaware County’s other children was obviously extreme. 

26. In July 2020 Plaintiff Connelly missed a ‘conciliation’ conference in Chester County, having improperly calendared the date, and Defendants Larissa Connelly and Potts pounced.

27. In a conspiracy whose object was to defraud Plaintiff Connelly of his parental rights, Defendants Potts and Connelly agreed/colluded/combined with corrupt hearing officer Defendant Tracy Christman to solicit a bogus, void, order illegally ‘rubber-stamped’ by Defendant Judge Sondergaard, e.g., Connelly v. Connelly, 2341 EDA 2020 (Pa. Cmmw. Ct. Oct. 15, 2021) (citing Ashford v. Ashford, 395 Pa. Super. 125, 132 (Pa. Super. Ct. 1990) (“In no case is the de novo procedure to be simply a review for error or a rubber stamp approval of the recommendation of the hearing officer”) (emphasis in the original)), cutting Plaintiff Connelly’s custody time with Plaintiff OWC in half, and putting various other unwarranted burdens on Plaintiff Connelly, all without having conducted a hearing, or made any findings of fact or conclusions of law. Connelly v. Connelly, 2341 EDA 2020 (Pa. Cmmw. Ct. Oct. 15, 2021). This was accomplished entirely outside of Plaintiff Connelly’s presence.

28. The most egregious of these terms was the limiting of Plaintiff Connelly’s reading time to fifteen minutes, which along with Defendant Larissa Connelly’s routine refusals to make Plaintiff OWC available, annihilated this special time, directly targeting the strong paternal bond between Plaintiff Connelly and Plaintiff OWC. See Exhibit PC-*** (❤️4myKids) (Plaintiff Connelly could no longer read his daughter to sleep).

29. In a subsequent and similarly lawless/bogus proceeding, Defendants Potts and Connelly again received carte blanche this time from Defendant Lombardi who recommended a draconian order unsupported by facts or law. The most egregious of the terms was the limiting of Plaintiff Connelly’s parenting time to six hours on every other Saturday under supervised custody at Plaintiff Connelly’s cost (he could not afford it). Plaintiff Connelly was thus granted a measly twelve pay-per-view hours per month with his child, plaintiff OWC under a void, illegally-solicited order.

30. At that time, there were no issues between Plaintiff Connelly, Defendant Dora Kassel, and their children, Plaintiffs Thomas P. Connelly, III, and EMC. In fact, Plaintiff Connelly and all three of his children along with a family friend, witness Elisabeth Germano, visited Hershey Park for a day in July of 2020 and had a great time. Exhibit PC-*** (🐒tomsKids!).

31. However, seeing an opportunity to gain an unfair advantage against Plaintiff Connelly, the Kassel Defendants and their corrupt, hack defendant attorneys began coordinating and conspiring with Defendant Larissa Connelly and her corrupt, hack attorneys, to prejudice Plaintiff Connelly’s position in both custody cases, even getting his three children together for visitation with one-another without his knowledge or consent causing Plaintiff Connelly severe emotional trauma which manifested physically.

32. What followed was a collusive and conspiratorial scheme by Defendants Larissa Connelly, Julie M. Potts, Craig B. Huffman, Dora L. Kassel, Lyn B. Schoenfeld, and Scott A. Lisgar in coordination with corrupt hearing officers, Defendants Richard E. Lombardi and Tracy Christman, defendant AOPC attorney Robert Krandel, defendant Disciplinary Counsel Anna Marie Ciardi, and numerous other defendant co-conspirators and bad-actors, to traffic illegally in Plaintiff Connelly’s plaintiff minor children, all to the aforesaid co-conspirators’ benefit and to Connelly and his children’s detriment, and to commit numerous acts of wire and mail fraud and tortious acts.

33. As a direct and proximate result of the defendants’ malicious, illegal, and unethical acts, Plaintiff Connelly has been prevented from seeing his children in person since the Fall of 2020, and Plaintiff Connelly and his children, Plaintiffs OWC, Thomas P. Connelly, III, and EMC have been injured economically, emotionally, mentally and physically thereby.

PRELIMINARY ALLEGATIONS

1. Each and every judge of Defendant Commonwealth of Pennsylvania is inherently biased due to the fact that he/she/they are elected and favor their constituents in deciding legal matters, and their elections/appointments are therefore null and void ab initio as in violation of Plaintiff Connelly’s right to due process of law under the United States Constitution (e.g., Amdt5, Amdt14) and similar provisions of the Pennsylvania Constitution. See, e.g., Exhibit PC-5 (amended petition for writ of habeas corpus against warden, berks county jail).

2. As a corollary to the foregoing, each and every order/opinion issued by each and every judge of Defendant Commonwealth of Pennsylvania is a nullity and void ab initio.

3. The foregoing is especially true with respect to Defendant Commonwealth of Pennsylvania’s magisterial district ‘judges’ who are not actually judges because they are not subject to Defendant Commonwealth of Pennsylvania’s Code of Judicial Conduct, Exhibit PC-37 (Pa. Code of Judicial Conduct) (“[t]his Code shall not apply to magisterial district judges and judges of the Traffic Court of the City of Philadelphia.”), and usually not even lawyers. See, e.g., Exhibit PC-*** (In PA, it’s easier to become a judge than a cosmetologist).

4. Similarly, Defendant Commonwealth of Pennsylvania’s domestic relations sections of its courts of common pleas are not courts but rather Pennsylvania’s corrupt executive (Defendant Shapiro) masquerading it/himself as the judicial branch, which, as will be proven herein, are nothing but its/his criminal co-conspirators. That domestic relations sections of the Court of Common Pleas are not courts is evidenced by, e.g., the fact that there is nowhere to file motions or pleadings in domestic relations matters (neither Defendant Commonwealth of Pennsylvania’s Prothonotaries nor its Clerks of Courts accept child-support-related applications).

5. Consequently each and every order recommended by masters/hearing officers and thereafter illegally ‘rubber stamped’ by common pleas judges, see, e.g., Connelly v. Connelly, 2341 EDA 2020 (Pa. Cmmw. Ct. Oct. 15, 2021) (citing Ashford v. Ashford, 395 Pa. Super. 125, 132 (Pa. Super. Ct. 1990) (“In no case is the de novo procedure to be simply a review for error or a rubber stamp approval of the recommendation of the hearing officer”) (emphasis in the original)) is a nullity and void ab initio as a matter of constitutional due process and/or the constitutional requirement of the separation of powers. E.g., United States v. Alvarez, 132 S. Ct. 2537 (2012).

6. The entirety of Defendant, Commonwealth of Pennsylvania's judicial branch in its present instantiation thus violates, in fact and law, the United States Constitution, specifically the Fifth Amendment, the Fourteenth Amendment, and the Separation of Powers Doctrine, e.g., United States v. Alvarez, 132 S. Ct. 2537 (2012).

7. The structure and form of the Pennsylvania judiciary having its roots in the Constitution of the Commonwealth of Pennsylvania, that Constitution, therefore, violates, in fact and law, the United States Constitution (e.g., Amdt5, Amdt14, Separation of Powers Doctrine), and must be deemed null and void.

8. Due to the criminal, tortious, and grossly negligent official conduct described herein, and the absence/failure of safeguards competent to adequately address such official misconduct, sovereign immunity in all its forms must be abolished throughout Defendant United States and its states/commonwealths, including but not limited to Defendant Commonwealth of Pennsylvania, in order to allow aggrieved private parties like Plaintiff Connelly and his long-suffering plaintiff children to be made whole. The ‘criminals in robes’ identified herein will never police themselves.

9. United States Supreme Court case law, e.g., Perez v. United States, 402 U.S. 146 (1971), so broadly interpreting the Commerce Clause of the United States Constitution as the ‘jurisdictional hook’ for the legislation/enforcement of federal criminal law, that the Tenth Amendment (and federalism along with it) has been rendered a nullity, especially in this era of persistent and complete digital interconnectivity, must be overruled, because the framers of the constitution specifically reserved ‘police powers’ singularly to the states by way of (1) the Tenth Amendment and (2) the Double Jeopardy Clause (“[n]o person shall be subject for the same offense to be twice put in jeopardy of life or limb”), which Clause clearly does not contemplate the two-sovereign doctrine (for which there is no rational or practical basis (one will suffice)).

10. Such case law violates these two fundamental constitutional principles and indeed the very federalist spirit of the constitution, and moreover constitutes ‘judicial legislation’ by hypocritical ‘strict constructionist’ Supreme Court Justices.

11. Consequently, federal law criminalizing marijuana possession and use, including, but not limited to, the Comprehensive Drug Abuse Prevention and Control Act of 1970, 21 U.S.C. §801–971 (1970) (“Controlled Substances Act” or “CSA”) is also unconstitutional pursuant to the Double Jeopardy Clause and/or the Tenth Amendment, and must be struck and deemed null and void.

12. There is no scientific, rational or legal basis under the United States Constitution to classify citizens on the basis of race. We are all African Americans, after all. See, e.g., Ulf Gyllensten et al., Paternal inheritance of mitochondrial DNA in mice, 352 Nature 255 (1991) (analyzing complete mtDNA sequences from diverse human populations and concluding that the greatest genetic diversity exists within African populations, supporting the “Out of Africa” theory of human origins).

13. There is no rational or legal basis under the United States Constitution to classify citizens on the basis of sex. The continued classification of citizens on the basis of sex is a form of ‘separate but equal’ treatment prohibited by Brown v. Bd. of Educ. of Topeka, 347 U.S. 483 (1954) (holding that state-sponsored segregation in public schools violated the Equal Protection Clause of the Fourteenth Amendment and overruling Plessy v. Ferguson, 163 U.S. 537 (1896)).  

14. The Establishment Clause of the First Amendment to the United States Constitution prohibits the government from establishing a religion, stating that "Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof.” U.S. Const. amend. I.

15. Discrimination on the basis of sex by Defendant United States violates the Establishment Clause, because, as noted, there is no rational basis for such discrimination, and therefore, its roots must be supernatural, e.g., religious. See, e.g., Gen. 1:27 (New International Version) ("So God created mankind in his own image, in the image of God he created them; male and female he created them."); Gen. 2:24 (New International Version) ("That is why a man leaves his father and mother and is united to his wife, and they become one flesh."); Matt. 19:4-6 (New International Version) ("(4) 'Haven't you read,' he replied, 'that at the beginning the Creator 'made them male and female,' (5) and said, 'For this reason a man will leave his father and mother and be united to his wife, and the two will become one flesh'? (6) So they are no longer two, but one flesh. Therefore what God has joined together, let no one separate.'"); Mark 10:6-9 (New International Version) ("(6) But at the beginning of creation God 'made them male and female.' (7) 'For this reason a man will leave his father and mother and be united to his wife, (8) and the two will become one flesh.' So they are no longer two, but one flesh. (9) Therefore what God has joined together, let no one separate."); Eph. 5:31 (New International Version) ("For this reason a man will leave his father and mother and be united to his wife, and the two will become one flesh.").

16. There is no rational basis under the United States Constitution to classify citizens on the basis of gender. This is a word that citizens invented to protest Defendant United States’ unlawful discrimination against them on the basis of assigned sex, over which they were given no control. Like race it has no scientific or rational basis, and like sex, gender-based government discrimination violates the Establishment Clause on the reasoning stated above. 

17. Each and every human/sentient defendant herein is sued both individually and as an officer/employee/agent/servant of the legal entities, also defendants herein, to whom/which they are responsible.

18. Each legal entity defendant herein is sued both individually and as officer/employee/agent/servant of the legal entities, defendants herein, to whom/which they are responsible, and for the conduct of its own human/sentient officers/employees/agents/servants in respondeat superior.

A BRIEF HISTORY OF TOM

1. Plaintiff Thomas Patrick Connelly Jr. JD (“Plaintiff Connelly” or “Connelly”) is an adult citizen of the Commonwealth of Pennsylvania.

2. Plaintiff Connelly was born extremely prematurely on January 16, 1974 at Abington Memorial Hospital to Thomas Patrick Connelly, IV, and Geraldine Marie Connelly (nee Lesher).

3. Plaintiff Connelly contracted pneumonia while in the ICU in an incubator, and his treating physicians gave him a five percent chance of surviving. Due to the love and kindness of his family and the Abington Memorial nursing staff (and likely the antibodies contained in his mother’s breast milk), he survived.

4. Plaintiff Connelly became interested in Zen Buddhism during college at Georgetown University, where he learned to sit zazen. After a particularly challenging flight in the T-34 Turbo Mentor at Naval Air Station Corpus Christi during flight training in the United States Navy, he found that he was physically exhausted but mentally very alert and at peace.

5. Plaintiff Connelly realized that during his flight, he was so task-saturated that he had no opportunity to ‘think’ about anything except flying the aircraft. This 'mindlessness' is the essence of zazen/zen. It is a projection outward into the universe and the concomitant literal annihilation of 'self' from one infinitesimal moment to the next.

6. This practice served Connelly well when he went on to fly the T-45 Goshawk at Naval Air Station Kingsville and still serves him to this day.

7. As he writes this, he has been alienated from his children for almost five years. The alienation from his children has been his greatest source of suffering (dukkha).

8. However, cognitive self-annihilation through zen/zazen precludes suffering because only the self, or ego, can suffer. Plaintiff Connelly’s practice therefore consists of meeting each infinitesimal moment as a newborn baby does–without memory or anticipation.

9. In that infinitesimal moment, Plaintiff Connelly is no longer Thomas Patrick Connelly Jr. JD. He is not even a father. He simply is: sum ergo cogito.

10. Jesus said to his disciples, “Whoever wants to be my disciple must deny themselves and take up their cross and follow me.” Matthew 16:24.

11. Consequently, as a spiritual (and now legal) matter Plaintiff Connelly rejects all labels except those he chooses to place upon himself. The only such labels that Plaintiff Connelly presently ‘owns’ are: (1) Father to his three children: Plaintiff Thomas P. Connelly III, Plaintiff EMC, and Plaintiff OWC; and (2) Disciple of Jesus Christ. He therefore demands strict proof of any additional labels applied herein, by this Court, or anyone else.

12. Plaintiff Connelly studies full-time at Liberty University in pursuit of a master’s degree in divinity. He hopes to reunite with his children, become a chaplain at Defendant, Department of Veterans Affairs and marry his fiance’ Ray Ann Baid Potutan of Tangub City Philippines.

THE DEFENDANTS

1. Defendant Administrative Office of the Pennsylvania Courts (“AOPC”) is an agency/subsidiary of Defendant Supreme Court of Pennsylvania with an office and place of business at 601 Comm. Ave. STE 2700 PO Box 62485 Harrisburg PA 17106-2485.

2. Defendant Alan Woodrow (“Woodrow”) is an adult citizen of the Commonwealth of Pennsylvania with an office or place of business at Defendant VAMC Coatesville 1400 Blackhorse Hill Rd. Coatesville PA 19320.

3. Defendant Alita A. Rovito JCCP (Pa. Atty. No. 49577) (“Rovito”) is an adult citizen of the Commonwealth of Pennsylvania with an office or place of business at Defendant County of Chester 201 W. Market St. West Chester PA 19380. 

4. Defendant Analisa S. Sondergaard JCCP (Pa. Atty. No. 74223) (“Sondergaard”) is an adult citizen of the Commonwealth of Pennsylvania with an office or place of business at Defendant County of Chester 201 W. Market St. West Chester PA 19380.

5. Defendant Andrea B. Tuominen Esq. (Pa. Atty. No. PA 81881) (“Tuominen”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Administrative Office of the Pennsylvania Courts 601 Comm. Ave. STE 2700 PO Box 62485 Harrisburg PA 17106-2485.

6. Defendant Angelo Martinez (“Martinez”) is an adult citizen of the State of Maryland with an office or place of business at Defendant Meeting Ground 168 W. Main St. Elkton MD 21921. 

7. Defendant Anna M. Ciardi Esq. (Pa. Atty. No. 206734) (“Ciardi”) is an adult citizen of the Commonwealth of Pennsylvania with an office or place of business at Defendant Commonwealth of Pennsylvania 601 Commonwealth Ave. STE 2700 PO Box 62485 Harrisburg PA 17106-2485. 

8. Defendant Anthony C. Epstein JDC (DC Atty. No. 250829) (“Epstein”) is an adult citizen of the District of Columbia with an office or place of business at Defendant Washington District of Columbia 1330 Connecticut Ave. NW Washington DC 20036-1795.

9. Defendant Archdiocese of Washington DC is an agency/subordinate department of Defendant Holy Roman Catholic and Apostolic Church with an office and place of business at Defendant Holy Roman Catholic and Apostolic Church 5001 Eastern Ave. Hyattsville MD 20782.

10. Defendant Arvil Prewitt (“Arvil Prewitt”) is an adult citizen of the Commonwealth of Pennsylvania residing at 180 Woods Rd. Oxford PA 19363. 

11. Defendant Arvil Wayne Prewitt (“Wayne Prewitt”) is an adult citizen of the Commonwealth of Pennsylvania residing at 180 Woods Rd. Oxford PA 19363.

12. Ashley Furniture Industries Inc. (“Ashley Furniture”) is a Wisconsin corporation with a headquarters at 1 Ashley Way Arcadia WI 54612.

13. Defendant Barbara A. Smith (“Prothonotary Smith”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant County of Lebanon 400 S. 8th St. Lebanon PA 17042. 

14. Defendant Barley Snyder LLP (“Barley Snyder Law Firm”) is a Pennsylvania limited liability partnership with an office and place of business at 1601 Cornwall Rd. Lebanon PA 17042. 

15. Defendant BCJ CO Captain Castro (“Castro”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant County of Berks 1287 County Welfare Rd. Leesport PA 19533.

16. Defendant BCJ CO Cunningham (“Cunningham”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant County of Berks 1287 County Welfare Rd. Leesport PA 19533.

17. Defendant Benjamin P. Novak Esq. (Pa. Atty. No. 326182) (“Novak”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Fowler Hirtzel McNulty & Spaulding LLC 1860 Charter Lane Ste. 201 Lancaster PA 17601.

18. Defendant Berks County Detectives (“Berks Detectives”) is an agency/subordinate department of Defendant County of Berks and/or Defendant Commonwealth of Pennsylvania with an office and place of business at Defendant County of Berks 633 Court St. Reading PA 19601.

19. Defendant Berks County Jail (“BCJ”) is an agency/subordinate department of Defendant County of Berks and/or Defendant Commonwealth of Pennsylvania with an office and place of business at Defendant County of Berks 633 Court St. Reading PA 19601. Defendant Berks County Jail is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of Defendant Jeffrey R. Smith and/or his subordinates (“BCJ Defendants”).

20. Defendant Berks County Office of the District Attorney (“Berks ODA”) is an agency/subordinate department of Defendant County of Berks and/or Defendant Commonwealth of Pennsylvania with an office and place of business at Defendant County of Berks 633 Court St. Reading PA 19601. Defendant Berks County Office of the District Attorney is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of Defendant John T. Adams Esq. and/or his subordinates (“Berks ODA Defendants”).

21. Defendant Berks County Office of the Public Defender (“Berks OPD”) is an agency/subordinate department of Defendant County of Berks and/or Defendant Commonwealth of Pennsylvania with an office and place of business at Defendant County of Berks 633 Court St. Reading PA 19601.

22. Defendant Berks County Sheriff (“Berks Sheriff”) is an agency/subordinate department of Defendant County of Berks and/or Defendant Commonwealth of Pennsylvania with an office and place of business at Defendant County of Berks 633 Court St. Reading PA 19601. Defendant Berks County Sheriff is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of Defendant Eric J. Weaknecht and/or his subordinates (“Berks Sheriff Defendants”).

23. Defendant Bonnie C. (“Bonnie C.”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant VAMC Coatesville 1400 Blackhorse Hill Rd. Bldg. Coatesville PA 19320. 

24. Defendant Bonnie Saddic (“Saddic”) is an adult citizen of the Commonwealth of Pennsylvania with a rental property at 11 W. Chestnut St. West Chester PA 19380. 

25. Defendant Booking Holdings Inc. (“Booking Holdings”) is a Connecticut corporation doing business as “priceline.com” with an office and place of business at 800 Connecticut Ave. Norwalk CT 06854. 

26. Defendant Borough of Cleona (“Cleona Borough”) is a political subdivision of Defendant County of Lebanon and/or Defendant Commonwealth of Pennsylvania with an office and place of business at 140 W. Walnut St. Cleona PA 17042. Defendant Borough of Cleona is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of Jeffrey J. Farneski and/or his subordinates (“Cleona Boro. Defendants”).

27. Defendant Boyd & Karver PC (“Boyd & Karver Law Firm”) is a Pennsylvania professional corporation with an office and place of business at 7 E. Philadelphia Ave. Boyertown PA 19512. Defendant Boyd & Karver PC is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of Defendants Craig S. Boyd Esq., Jeffrey C. Karver Esq.,and/or Jeffrey R. Boyd Esq. 

28. Defendant Bradford H. Charles JCCP (Pa. Atty. No. 34346) (“Judge Charles” or “Charles”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at 400 S. 8th St. Lebanon PA 17042. 

29. Defendant Brian J. McCabe PSP (“Trooper McCabe” or “McCabe”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Commonwealth of Pennsylvania 2 Moxley Rd. Avondale PA 19311.

30. Defendant Carmen R. Faneytt Brito MD (“Dr. Faneytt” or “Faneytt”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant VAMC Lebanon 1700 S. Lincoln Ave. Lebanon PA 17042. 

31. Defendant Central Berks Regional PD (“CBRPD”) is an agency/subordinate department of Defendant County of Berks and/or Defendant Commonwealth of Pennsylvania with an office or place of business at 2147 Perkiomen Ave. Reading PA 19606. Defendant Central Berks Regional PD  is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of Defendant J. Doe Central Berks Regional PD 1. 

32. Defendant Charles G. Resnick Esq. (NJ Atty. No. 022201977) (“Resnick”) is an adult citizen of Defendant State of New Jersey with an office and place of business at 1060 Kings Highway N. Cherry Hill NJ 08033.

33. Defendant Chester County Office of the District Attorney (“Chester County ODA”) is an agency/subordinate department of Defendant County of Chester and/or Defendant Commonwealth of Pennsylvania with an office or place of business at 201 W. Market St. West Chester PA 19380. 

34. Defendant Chester County Office of the Public Defender (“Chester County OPD”) is an agency/subordinate department of Defendant County of Chester and/or Defendant Commonwealth of Pennsylvania with an office or place of business at 201 W. Market St. West Chester PA 19380.

35. Defendant Christa G. (“Christa G.”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant VAMC Coatesville 1400 Blackhorse Hill Rd. Bldg. Coatesville PA 19320. 

36.  Defendant Christie M. Billman Esq. (Pa. Atty. No. 90187) (“PD Billman” or “Billman”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant County of Berks 633 Court St. Reading PA 19601.

37. Defendant Christopher Steck SJ (“Steck”) is an adult citizen of Washington District of Columbia with an office and place of business at Defendant Georgetown University 3700 O St. NW Washington DC 20057.

38. Defendant Claire Domenick “Claire Domenick” is an adult citizen of the Commonwealth of Pennsylvania with commercial premises Defendant Little Oley Tavern located at 2068 Farmington Ave. Boyertown PA 19512. She is married to Defendant Kenneth Domenick. Each of them is sued as a tenant in the entirety.

39. Defendant Colin R. Boyer Esq. (Pa. Atty. No. 94500) (“ADA Boyer” or “Boyer”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Berks County 633 Court St. Reading PA 19601. 

40. Defendant Colleen S. Gallo Esq. (Pa. Atty. No. 79994) (“Attorney Gallo” or “Gallo”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Barley Snyder LLP 1601 Cornwall Rd. Lebanon PA 17042. 

41. Defendant Commonwealth of Pennsylvania (“Comm. of Pennsylvania” or “Comm. of Pa.”) is a commonwealth of Defendant United States composed of three branches, see Pa. Const., with an office and place of business at 16th Flr. Strawberry Square Harrisburg PA 17120. Defendant Commonwealth of Pennsylvania is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of Defendants County of Berks, County of Bucks, County of Chester, County of Delaware, County of Lebanon, Debra B. Todd CJ,  Estate of Max Baer, Josh D. Shapiro Esq., PrimeCare Medical Inc. (“Commonwealth of Pennsylvania Defendants”), and any subordinates.

42. Defendant County of Berks (“Berks County”) is a county of Defendant Commonwealth of Pennsylvania with an office and place of business at 633 Court St. Reading PA 19601. A board of commissioners is responsible for the county's executive and legislative functions. Defendant County of Berks is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of Defendants Berks County Jail, Berks County Office of the District Attorney, Berks County Office of the Public Defender, Berks County Sheriff, Central Berks Regional PD, Eastern Berks Regional PD, Estate of Paul M. Yatron, John T. Adams Esq., Keith A. McConnell Esq., Mary T. Johnson JCCP, Sandra L. Fegley MDJ, Steven M. Chieffo MDJ, Township of Alsace, Township of Amity, Township of Douglass, and Township of Lower Alsace (“Berks County Defendants”), and any additional subordinates. 

43. Defendant County of Bucks (“Bucks County”) is a county of Defendant Commonwealth of Pennsylvania with an office and place of business at 55 E. Court St. #5 Doylestown PA 18901. Bucks County is governed by a combination of a board of commissioners, row officers, and municipal governments. The District Attorney of Bucks County is an elected row officer. Defendant County of Bucks PA is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of Defendants J. Doe Bucks Cty. ADA 1 and Regina Armitage MDJ (“Bucks County Defendants”). 

44. Defendant County of Camden (“Camden County”) is a county of Defendant State of New Jersey with an office and place of business at 520 Market Street 5th Flr. Camden NJ 08103. Defendant County of Camden NJ is liable in respondeat superior for the tortious, negligent, grossly negligent and/or criminal conduct of defendants Marilu Burgos and Sherri L. Schweitzer JSC (“Camden County Defendants”). 

45. Defendant County of Cecil (“Cecil County”) is a county of Defendant State of Maryland with an office and place of business at 200 Chesapeake Blvd. Elkton MD 21921. Defendant County of Cecil MD is liable in respondeat superior for the tortious, negligent, grossly negligent and/or criminal conduct of Defendants Town of Elkton and Meeting Ground d/b/a CCMS (“Cecil County Defendants”), or in the alternative, is sued as a necessary party in qui tam along with same, who upon information and belief, was the recipient of county funds. 

46. Defendant County of Chester (“Chester County”) is a county of Defendant Commonwealth of Pennsylvania with an office and place of business at 313 W. Market St. Ste. 6702 West Chester PA 19380-0991. Defendant County of Chester is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of Defendants Chester County Office of the Public Defender, Gregory J. Marshall Esq., John L. Hall Jr. JCCP, Nathan M. Schenker Esq., Richard E. Lombardi Esq., Suzie Marker, Tracy L. Christman Esq., and *** (“Chester County Defendants”). 

47. Defendant County of Delaware PA (“Delaware County”) is a county of Defendant Commonwealth of Pennsylvania with an office and place of business at 201 W. Front St. Media PA 19063. Defendant County of Delaware PA is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of Defendants Gerald C. Montella Esq., Kevin F. Kelly JCCP, and *** (“Delaware County Defendants”).

48. Defendant County of Lebanon (“Lebanon County”) is a county of Defendant Commonwealth of Pennsylvania with an office and place of business at 735 Cumberland St. Lebanon PA 17042-6794. Defendant County of Lebanon PA is liable in respondeat superior for the tortious, negligent, grossly negligent and/or criminal conduct of Defendants Barbara A. Smith, Borough of Cleona, Bradford H. Charles JCCP, Pier N. Hess Esq., and *** (“Lebanon County Defendants”).

49. Defendant Craig B. Huffman Esq. (Pa. Atty. No. 82085) (“Attorney Huffman” or “Turd Ferguson” “Huffman”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Eckell Sparks Levy Auerbach Monte Sloane Matthews & Auslander PC 113 East Evans St. Matlack Bldg. STE D-1 West Chester PA 19380. 

50. Defendant Craig Cook (“SW Cook” or “Cook”) is an adult citizen of the State of Maryland with an office and place of business at Defendant VAMC Perry Point 361 Boiler House Rd. Perry Point MD 21902-1103. 

51. Defendant Craig S. Boyd Esq. (“Attorney Craig Boyd”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Boyd & Karver PC 7 E. Philadelphia Ave. Boyertown PA 19512. He is sued as an officer or shareholder of Defendant Defendant Boyd & Karver PC and is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of Defendant Jeffrey R. Boyd Esq.  

52. Defendant Crystal McClain (“EO McClain” or McClain”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant County of Delaware 201 W. Market St. West Chester PA 19380. 

53. Defendant Cynthia Kayati-Brown-Tabaei (“Kayati-Brown”) is an adult citizen of the State of New Jersey residing at 24 Hathaway Ct. Marlton NJ 08053.

54. Defendant David K. Bifulco Esq. (Pa. Atty. No. 310038) (“Attorney Bifulco” or “Bifulco”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Law Office of David K. Bifulco 205 W. Broad St. Bethlehem PA 18018. 

55. Defendant David McNulty Esq. (“Master McNulty” or “McNulty”) is an adult citizen of the Commonwealth of Pennsylvania with an office of place of business at Defendant County of Delaware 201 W. Front St. Media PA 19063.

56. Defendant Deborah S. Ryan JCCP (Pa. Atty. No. 82302) (“Ryan”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant County of Chester 201 W. Market St. West Chester PA 19380.

57. Defendant Debra B. Todd CJ (Pa. Atty. No. 37537) (“Justice Todd” or “Todd”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Commonwealth of Pennsylvania 601 Commonwealth Ave #1500 Harrisburg PA 17120. Defendant Debra B. Todd CJ is liable in respondeat superior for the tortious, negligent, grossly negligent and/or criminal conduct of the following defendants and their subordinates Administrative Office of the Pennsylvania Courts, Andrea B. Tuominen Esq., Barley Snyder LLP, Boyd & Karver PC, Disciplinary Board of the Supreme Court of Pa., Eckell Sparks et al., Feeman Law Offices, Fowler Hirtzel McNulty & Spaulding LLC, Geoffrey H. Moulton Jr. Esq., Goldman Law Offices, Judges of the Commonwealth of Pennsylvania, Justices of the Supreme Court of Pennsylvania, Keller Lisgar & Williams LLP, Law Office of David K. Bifulco, Lento Law Group PC, Manley Deas Kochalski LLC, Margolis Edelstein et al., Marshall Dennehey PC, Miller Law Firm PC, Potts Shoemaker & Grossman LLC, Regina Armitage MDJ, Robert J. Krandel Esq., Sandra L. Fegley MDJ, Schoenfeld Surkin Chupein & DeMis PC, Steven M. Chieffo MDJ, The Peters Firm PLLC, Thomas J. Farrell Esq., and *** (“Todd Defendants”).

58. Defendant Denis R. McDonough (“McDonough”) is an adult citizen of the District of Columbia with an office and place of business (for all relevant times) at Department of Veterans Affairs 810 Vermont Ave NW Washington DC 20420. Defendant Denis R. McDonough  is liable in respondeat superior for the tortious, negligent, grossly negligent and/or criminal conduct of Defendants Jeffrey A. Beiler II, Jennifer Harkins MS FACHE, Jonathan R. Eckman PE, Michael Heimall FACHE, Vamsee Potluri, Veterans Affairs Medical Center Coatesville PA, Veterans Affairs Medical Center Lebanon PA, Veterans Affairs Medical Center Perry Point MD, Veterans Affairs Medical Center Washington DC, Veterans Affairs Medical Center Wilmington DE and their subordinates (“McDonough Defendants”). 

59. Defendant Dept. of Veterans Affairs (“VA”) is an agency of the executive branch of Defendant United States of America with an office and place of business at 810 Vermont Ave NW Washington DC 20420.

60. Defendant Dilipkumar J. Joshi MD (“Dr. Joshi” or “Joshi”) is an adult citizen of the State of Delaware with an office and place of business at Defendant The Rockford Center 100 Rockford Dr. Newark DE 19713. 

61. Defendant Dillon L. Milicevic (“Dillon Milicevic”) is an adult citizen of the Commonwealth of Pennsylvania and the owner of real property at 23 Petsch Rd. Reading PA 19606. Dillon Milicevic was at all relevant times married to Defendant Kelsey P. Milicevic. They are each sued as a tenant in the entirety.

62. Defendant Disciplinary Board of the Supreme Court of Pa. (“Pa. Disciplinary Board”) is an agency/subsidiary of Defendant Supreme Court of Pennsylvania with an office and place of business at 601 Commonwealth Ave. STE 2700 PO Box 62485 Harrisburg PA 17106-2485.

63. Defendant Dora L. Kassel VMD (“Dora Kassel”) is an adult citizen of the Commonwealth of Pennsylvania residing at 819 Pleasant Hill Rd. Wallingford PA 19086. Dora Kassel was at all relevant times married to Defendant Scott Kassel. They are each sued as a tenant in the entirety.

64. Defendant Douglass Township PD (“Douglass Twp. PD”) is an agency/subordinate department of Defendant Douglass Township with an office and place of business at 1068 Douglass Dr. Boyertown PA 19512. Defendant Douglass Township PD is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of Defendants J. Does Douglass Twp. PD 1-5, Ryan M. Foltz, and/or their subordinates (“Douglass Twp. PD Defendants”). 

65. Defendant Eastern Berks Regional PD (“EBRPD”) is an agency/subordinate department of Defendant County of Berks and/or Defendant Commonwealth of Pennsylvania with an office and place of business at 16 W Philadelphia Ave. Boyertown PA 19512. Defendant Eastern Berks Regional PD  is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of Defendants J. Does Eastern Berks Regional PD 1-5 and/or their subordinates (“EBRPD Defendants”). 

66. Defendant Eckell Sparks Levy Auerbach Monte Sloane Matthews & Auslander PC (“Eckell Sparks”) is a Pennsylvania professional corporation with an office and place of business at 113 East Evans St. Matlack Bldg. STE D-1 West Chester PA 19380. 

67. Defendant Edward E. Brooks (“Edward Brooks” or “Ed Brooks”) is an adult citizen of the Commonwealth of Pennsylvania residing at 149 Bingaman Rd. Reading PA 19606. Edward Brooks was at all relevant times married to Defendant Jennifer A. Brooks. They are each sued as a tenant in the entirety.

68. Defendant Elizabeth T. Hey USMJ (Pa. Atty. No. 56464) (“Judge Hey” or “Hey”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant United States 601 Market St. Philadelphia PA 19106.

69. Defendant Elkton Police Department (“Elkton PD”) is an agency/subordinate department of Defendant Town of Elkton with an office and place of business at 100 Railroad Ave. Elkton MD 21921.

70. Defendant Eric J. Weaknecht (“Sheriff Weaknecht” or “Weaknecht”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant County of Berks 633 Court St. 3rd Flr. Reading PA 19601.

71. Defendant Estate of Joselyn C. Kayati (“Kayati Estate”) is the estate of Joselyn C. Kayati, who passed away on August 10 2022. The administrator of the estate is Defendant Marc A. Lario Esq. with an office and place of business at Defendant Marc A. Lario and Associates 89 N. Hadden Ave. Haddonfield NJ 08033.

72. Defendant Estate of Max Baer (“Baer Estate”) is the estate of Max Baer, formerly Chief Justice of Defendant Pennsylvania Supreme Court, who became compost on September 30, 2022. The Baer Estate is sued herein via Defendant Justice Max Baer Memorial Fund 255 King Richard Dr. Canonsburg PA 15317. Defendant Estate of Max Baer is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of deceased Chief Justice of Defendant Commonwealth of Pennsylvania’s Supreme Court Max Baer.

73. Defendant Estate of Paul M. Yatron (“Yatron Estate”) is the estate of Paul M. Yatron, formerly the president judge of Defendant Berks County’s Court of Common Pleas, who became compost on December 6, 2022. Further details are to be determined (TBD). Defendant Estate of Paul M. Yatron is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of deceased President Judge of the Berks County Court of Common Pleas Paul M. Yatron and/or his subordinates.

74. Defendant Feeman Law Offices (“Feeman Law Firm”) is a Pennsylvania law firm of unknown corporate status with an office and place of business at 815 Cumberland St #200 Lebanon PA 17042.

75. Defendant Firefly Legal Inc. (“Firefly Legal”) is an Illinois corporation with an office and place of business at 19150 S. 88th Ave. Mokena IL 60448.

76. Defendant FirstEnergy Corp. d/b/a Met-Ed (“FirstEnergy”) is an Ohio corporation with an office and place of business at 76 S Main St. Akron OH 44308-1890.

77. Defendant Fowler Hirtzel McNulty & Spaulding LLC (“FHMS”) is a Pennsylvania professional limited liability corporation with an office and place of business at 1860 Charter Lane Ste. 201 Lancaster PA 17601.

78. Defendant Gabriel Longhi PsyD  (“Longhi”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Veterans Affairs Medical Center Coatesville PA 1400 Blackhorse Hill Rd. Coatesville PA 19320.

79. Defendant Geoffrey H. Moulton Jr. Esq. (Pa. Atty. No. PA 46456) (“Administrator Moulton” or “Moulton”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business (for all relevant times) at Defendant Administrative Office of the Pennsylvania Courts 601 Comm. Ave. STE 2700 PO Box 62485 Harrisburg PA 17106-2485.

80. Defendant Georgetown University (“Georgetown”) is a Washington District of Columbia corporation, see Charter of Georgetown University (1815) (as amended by Public Law 89-631, 89th Congress, H.R. 16863, October 4, 1966), with an office and place of business at 3700 O St. NW Washington DC 20057.

81. Defendant Gerald C. Montella Esq. (“Administrator Montella” or “Montella”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at 201 W. Front St. Media PA 19063. Defendant Gerald C. Montella Esq. is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of David McNulty Esq. and/or his non party defendant subordinates (“Montella Defendants”).

82. Defendant Goldman Law Offices (“Goldman Law Firm”) is a Pennsylvania law firm of unknown corporate form with an office and place of business at 90 E. State St. Doylestown PA 18901.

83. Defendant Gregory J. Marshall Esq. (Pa. Atty. No. 47128) (“Master Marshall” or “Marshall”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant County of Chester 201 W. Market St. West Chester PA 19380.

84. Defendant Gregory S. Hirtzel Esq. (Pa. Atty. No. 56027) (“Attorney Hirtzel” or “Hirtzel”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Fowler Hirtzel McNulty & Spaulding LLC 1860 Charter Lane Ste. 201 Lancaster PA 17601.

85. Defendant Holy Roman Catholic and Apostolic Church (“Holy See”) is a criminal enterprise with an office and place of business at Casa Santa Marta 00120 Vatican City. The Holy See is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of *** (“Catholic Defendants”).

86. Defendant Howard T. Root (“Root”) is an adult citizen of the Commonwealth of Pennsylvania residing at 435 Kauffman Rd. Annville PA 19606.

87. Defendant J. Doe Berks Cty. ADA 1 (“Berks ADA 1”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Berks County 633 Court St. Reading PA 19601. 

88. Defendant J. Doe Bucks Cty. ADA 1 (“Bucks ADA 1”)  is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Bucks County 55 E. Court St. #5 Doylestown PA 18901.

89. Defendant J. Doe Central Berks Regional PD 1 (“CBRPDO 1”) is a police officer of Defendant Central Berks Regional PD with an office and place of business at 2147 Perkiomen Ave. Reading PA 19606.

90. Defendant J. Doe VAMC Lebanon SW 1 (“Lebanon VAMC SW 1”) is a social worker agent/employee of Defendant Veterans Affairs Medical Center Lebanon PA with a first name of "Mikki" or similar with an office and place of business 1700 S. Lincoln Ave. Lebanon PA 17042.

91. Defendant J. Doe Wash. DC ADA 1 (“DC ADA 1”) is an agent/employee of Defendant United States with an office and place of business at  601 D Street NW Washington DC 20004.

92. Defendants J. Does Amity Twp. Police Department 1-5 (“J. Does Amity Twp. PD”) are police officers of Defendant Township of Amity with an office and place of business at 2004 Weavertown Rd. Douglassville PA 19518.

93. Defendants  J. Does Berks Co. Jail 1-5 (“J. Does BCJ”) are corrections officers of Defendant County of Berks with an office and place of business at 1287 County Welfare Rd. Leesport PA 19533.

94. Defendants J. Does Berks Co. Sheriff 1-5 (“J. Does BCS”) are sheriff’s officers of Defendant County of Berks with an office and place of business at 633 Court St. 3rd Flr. Reading PA 19601. 

95. Defendants J. Does Cleona Boro. PD 1-5 (“J. Does Cleona PD”) are police officers of Defendant Borough of Cleona with an office and place of business 140 W. Walnut St. Cleona PA 17042.

96. Defendants J. Does Douglass Twp. PD 1-5 (“J. Does Douglass Twp. PD”) are police officers of Defendant Douglass Township with an office and place of business at 1068 Douglass Dr. Boyertown PA 19512.

97. Defendants J. Does Eastern Berks Regional PD 1-5 (“J. Does EBRPD”) 16 W Philadelphia Ave. Boyertown PA 19512.

98. Defendants J. Does Elkton PD 1-10 (“J. Does Elkton PD”) are police officers of Defendant Town of Elkton with an office and place of business at 100 Railroad Ave. Elkton MD 21921.

99. Defendants J. Does Georgetown U. Campus PD 1-10 (“J. Does GU Campus PD”) are agents/employees of Defendant Georgetown University with an office and place of business at 3700 O St. NW Washington DC 20057.

100. Defendants J. Does Georgetown U. Medical Cntr. ED 1-10 (“J. Does GU Med. Cntr. ED”) are medical-professional agents/employees of Defendant Georgetown University with an office and place of business at 3700 O St. NW Washington DC 20057.

101. Defendants J. Does MDC 23-2-03 1-5 (“J. Does MDC 23-2-03”) are agents/employees of Defendant County of Berks and/or Defendant Commonwealth of Pennsylvania with an office and place of business at 6112 Perkiomen Ave. Birdsboro PA 19508.

102. Defendants J. Does Pennsylvania State Police Troopers 1-10 (“J. Does PSP Troopers”) are agents/employees of Defendant Commonwealth of Pennsylvania with an office and place of business at Defendant Pennsylvania State Police 600 Kenhorst Blvd. Reading PA 19611-1700. 

103. Defendants J. Does The Rockford Center 1-5 (“J. Does Rockford Center”) are medical-professional agents/employees of Defendant The Rockford Center with an office and place of business at 100 Rockford Dr. Newark DE 19713.

104. Defendants J. Does Tower Health 1-10 (“J. Does Tower Health”) are agents/employees of Defendant Tower Health with an office and place of business at Defendant Tower Health  420 S. 5th Ave. West Reading PA 19611.

105. Defendants J. Does US Marshals 1-5 (“J. Does US Marshals”) are agents/employees of Defendant United States Marshal Service with an office and place of business at Defendant United States Marshal Service 50 Irving St NW Washington DC 20422.

106. Defendants J. Does VAMC Coatesville 1-20 (“J. Does VAMC Coatesville”) are medical-professional agents/employees of Defendant Veterans Affairs Medical Center Coatesville PA with an office and place of business at Defendant US Marshal Service 1400 Blackhorse Hill Rd. Coatesville PA 19320.

107. Defendants J. Does VAMC Wash. DC ED 1-10 (“J. Does VAMC Washington DC ED”) are agents of Defendant United States with an office and place of business at VAMC Washington DC 50 Irving St NW Washington DC 20422.

108. Defendants J. Does VAMC Wash. DC PD 1-5 (“J. Does VAMC Washington DC PD”)  are agents of Defendant United States with an office and place of business at VAMC Washington DC 50 Irving St NW Washington DC 20422.

109. Defendants J. Does VAMC Wilmington ED 1-10 (“J. Does VAMC Wilmington ED”) are agents of Defendant United States with an office and place of business at VAMC Wilmington 1601 Kirkwood Hwy. Wilmington DE 19805.

110. Defendants J. Does VOTR 1-5 (“J. Does VOTR”) are agents of Defendant Veterans on the Rise with an office and place of business at Defendant VOTR 5002 Sheriff Rd. NE Washington DC 20019.

111. Defendants J. Does Wash. DC Metro. PD 1-20 (“J. Does DC Metro. PD”) are agents/employees of Defendant Washington DC Metro. PD with an office and place of business at Washington DC Metro. PD 300 Indiana Ave. NW Washington DC 20001.

112. Defendant Jacqueline C. Cody JCCP (Pa. Atty. No. 31337) (“Judge Cody” or “Cody”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant County of Chester 201 W. Market St. West Chester PA 19380.

113. Defendant James E. Gavin JCCP (Pa. Atty. No. 52827) (“Judge Gavin” or “Gavin”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant County of Berks 633 Court St. Reading PA 19601.

114. Defendant James Green PSP (“Trooper Green” or “Green”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Pennsylvania State Police 600 Kenhorst Blvd. Reading PA 19611-1700.

115. Defendant Janet C. Prewitt (“Janet Prewitt”) is an adult citizen of the Commonwealth of Pennsylvania residing at 180 Woods Rd. Oxford PA 19363.

116. Defendant Jeffrey A. Beiler II (“Director Beiler” or “Beiler”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant VAMC Lebanon 1700 S. Lincoln Ave. Lebanon PA 17042.

117. Defendant Jeffrey C. Karver Esq. (“Attorney Karver” or “Karver”) is an agent/employee/officer/shareholder of Defendant Boyd & Karver PC with an office and place of business at Defendant Boyd & Karver PC  7 E. Philadelphia Ave. Boyertown PA 19512.

118. Defendant Jeffrey J. Farneski (“Chief Farneski” or “Farneski”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Borough of Cleona 140 W. Walnut St. Cleona PA 17042. Defendant Jeffrey J. Farneski is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of J. Does Cleona Boro. PD 1-5, Robert Henning Jr., and/or their subordinates (“Farneski Defendants”). 

119. Defendant Jeffrey R. Boyd Esq. (Pa. Atty. No. 89033) (“Attorney Boyd”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Boyd & Karver PC 7 E. Philadelphia Ave. Boyertown PA 19512.

120. Defendant Jeffrey R. Smith (“Warden Smith”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant County of Berks 1287 County Welfare Rd. Leesport PA 19533.

121. Defendant Jennifer A. Brooks (“Jennifer Brooks”) is an adult citizen of the Commonwealth of Pennsylvania residing at  149 Bingaman Rd. Reading PA 19606.

122. Defendant Jennifer Flemister Esq. (Pa. Atty. No. 326103) (“DC Flemister” or “Flemister”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Commonwealth of Pennsylvania 601 Commonwealth Ave. STE 2700 PO Box 62485 Harrisburg PA 17106-2485.

123. Defendant Jennifer Harkins MS FACHE (“Director Harkins” or “Harkins”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant VAMC Coatesville 1400 Blackhorse Hill Rd. Coatesville PA 19320.

124. Defendant Jennifer L. Reed (“SW Reed” or “Reed”) is an adult citizen of the State of Maryland with an office and place of business at Defendant VAMC Perry Point 361 Boiler House Rd. Perry Point MD 21902-1103.

125. Defendant Jesse T. Kirsch (“PA Kirsch”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant PrimeCare Medical Inc. 3940 Locust Ln. Harrisburg PA 17109.

126. Defendant John B. Nevius JCCP (Pa. Atty. No. 93094) (“Judge Nevius” or “Nevius”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant County of Berks 633 Court St. Reading PA 19601.

127. Defendant John C. Tylwalk JCCP (“Judge Tylwalk” or “Tylwalk”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant County of Lebanon 400 S. 8th St. Lebanon PA 17042. Defendant John C. Tylwalk JCCP is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of Defendants Barbara A. Smith, Bradford H. Charles JCCP and/or additional subordinates (“Tylwalk Defendants”).

128. Defendant John E Markey PsyD LLC (“Markey LLC”) is a Commonwealth of Pennsylvania professional limited liability company with an office and place of business at 80 N. Main St. #1C Doylestown PA 18901.

129. Defendant John E. Markey PsyD (“Dr. Markey” or “Markey”)  is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant John E Markey PsyD LLC 80 N. Main St. #1C Doylestown PA 18901.

130. Defendant John J. DeGioia (“DeGioia”) is an adult citizen of the District of Columbia with an office and place of business at Defendant Georgetown University 3700 O St. NW Washington DC 20057.

131. Defendant John L. Hall Jr. JCCP (Pa. Atty. No. 38455) (“Judge Hall” or “Hall”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant County of Chester 201 W. Market St. West Chester PA 19380. Defendant John L. Hall Jr. JCCP is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of Defendants Alita A. Rovito JCCP, Analisa S. Sondergaard JCCP, Gregory J. Marshall Esq., Jacqueline C. Cody JCCP, Katherine BL Platt JCCP, Richard E. Lombardi Esq., Suzie Marker, Tracy L. Christman Esq., and *** and/or their subordinates (“Hall Defendants”).

132. Defendant John M. Gallagher USDJ (Pa. Atty. No. PA 78697) (“Judge Gallagher” or “Gallagher”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant United States 504 W. Hamilton St. STE 4701 Allentown PA 18101.

133. Defendant John T. Adams Esq. (Pa. Atty. No. 59482) (“DA Adams” or “Adams”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant County of Berks 633 Court St. Reading PA 19601. Defendant John T. Adams Esq. is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of Defendants Berks County Detectives, Colin R. Boyer Esq., J. Doe Berks Cty. ADA 1, Kathryn L. Lehman Esq., Kevin F. Howard Esq., Pamela Mathias, and *** and/or their subordinates (“Adams Defendants”).

134. Defendant Jonathan R. Eckman PE (“Director Eckman” or “Eckman”) is an adult citizen of the State of Maryland with an office and place of business at Defendant VAMC Perry Point 59 Avenue D Perry Point MD 21902.

135. Defendant Jorge L. Melendez (“Melendez”) is an adult citizen of the State of Maryland with an office and place of business at Defendant Meeting Ground 168 W. Main St. Elkton MD 21921.

136. Defendant Jorge Mario Bergoglio (“The Pope”) is an adult citizen of Vatican City with an office and place of business at Casa Santa Marta 00120 Vatican City.

137. Defendant Joseph D. Lento Esq. (Pa. Atty. No. PA 208824) (“Attorney Lento” or “Lento”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Lento Law Group PC 1500 Walnut St. Ste. 500 Philadelphia PA 19102.

138. Defendant Joseph H. Kayati Jr. (“Joe Kayati” or “Kayati”) is an adult citizen of the State of New Jersey residing at 867 Old White Horse Pike Waterford Works NJ 08089.

139. Defendant Joseph Robinette Biden Jr. (“Biden”) is an adult citizen of the State of Delaware with an office and place of business at PO Box 7819 Wilmington DE 19803. Defendant  Joseph Robinette Biden Jr. is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of Defendants Denis R. McDonough, Merrick B. Garland, Ronald L. Davis, and *** (“Biden Defendants”).

140. Defendant Josh D. Shapiro Esq. (Pa. Atty. No 90101) (“Governor Shapiro” or “Shapiro”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Commonwealth of Pennsylvania 508 Main Capitol Building Harrisburg PA 17120. Defendant Josh D. Shapiro Esq. is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of Defendants Robert Evanchick PSP, Valerie A. Arkoosh MD MPH, and *** (“Shapiro Defendants”).

141. Defendant Josh JT Byrne Esq. (Pa. Atty. No. 85474) (“Attorney Byrne” or “Byrne”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Marshall Dennehey PC 138-140 W. Gay St. West Chester PA 19380.

142. Defendants Judges of the Commonwealth of Pennsylvania (“Pa. Judiciary”) are adult citizens of the Commonwealth of Pennsylvania with an office and place of business at  601 Commonwealth Ave. STE 2700 PO Box 62485 Harrisburg PA 17106-2485.

143. Defendants Judges of the US Court of Appeals for the Third Circuit (“3rd Cir. COA Judges”) are adult citizens of the United States with an office and place of business at 601 Market St. Philadelphia PA 19106.

144. Defendant Julie M. Potts Esq. (Pa. Atty. No 92940) (“Attorney Potts” or “Potts”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Potts Schoemaker & Grossman LLC 138-140 W. Gay St. West Chester PA 19380. 

145. Defendant Justice Max Baer Memorial Fund (“Baer Memorial Fund”) is funded by Defendant Estate of Max Baer and has an office and place of business at 255 King Richard Dr. Canonsburg PA 15317.

146. Defendants Justices of the Supreme Court of Pennsylvania (“Pa. Supreme Court”) are: Christine Donohue; Daniel D. McCaffery; David N. Wecht; Debra Todd; Kevin M. Dougherty; P. Kevin Brobson; Sallie Updyke Mundy (collectively “turds”). Each is sued in his/her individual and professional capacity.

147. Defendant Karen S. Marston USDJ (Pa. Atty. No. 325552) (“Judge Marston” or “Marston”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant United States 601 Market St. Philadelphia PA 19106.

148. Defendant Katherine BL Platt JCCP (Pa. Atty. No. 23868) (“Judge Platt” or “Platt”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant County of Chester 201 W. Market St. West Chester PA 19380.

149. Defendant Kathryn L. Lehman Esq. (Pa. Atty. No. 309410) (“ADA Lehman” or “Lehman”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant County of Berks 633 Court St. Reading PA 19601.

150. Defendant Kavell Whitehead (“Whitehead”) is an adult citizen of the District of Columbia with an office and place of business at Defendant Veterans on the Rise 5002 Sheriff Rd. NE Washington DC 20019. 

151. Defendant Keith A. McConnell Esq. (Pa. Atty. No. 66339) (“PD McConnell” or “McConnell”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant County of Berks 633 Court St. Reading PA 19601. Defendant Keith A. McConnell Esq. is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of Defendants Berks County Office of the Public Defender, Christie M. Billman Esq. and/or their subordinates (“Berks OPD Defendants”).

152. Defendant Keller Lisgar & Williams LLP (“KLW Law Firm”) is a Pennsylvania limited liability professional partnership with an office and place of business at 18 W. Front St. Media PA 19063.

153. Defendant Kelsey P. Milicevic (“Kelsey Milicevic”) is an adult citizen of the Commonwealth of Pennsylvania owning real property located at 23 Petsch Rd. Reading PA 19606. She is married to Defendant Dillon L. Milicevic, and each of them is sued as a tenant in the entirety.

154. Defendant Kenneth Domenick (“Ken Domenick”) is an adult citizen of the Commonwealth of Pennsylvania owning real property located at Defendant Little Oley Tavern 2068 Farmington Ave. Boyertown PA 19512. Kenneth Domenick is married to Defendant Claire Domenick. Each of them is sued as a tenant in the entirety.

155. Defendant Kevin F. Howard Esq. (Pa. Atty. No. 80834) (“ADA Howard” or “Howard”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant County of Berks 633 Court St. Reading PA 19601.

156. Defendant Kevin F. Kelly JCCP (Pa. Atty. No. 43598) (“Judge Kelly” or “Kelly”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant County of Delaware 201 W. Front St. Media PA 19063.

157. Defendant Larissa C. Connelly (“Larissa Connelly”) is an adult citizen of the Commonwealth of Pennsylvania residing at 180 Woods Rd. Oxford PA 19363. She is the biological mother of Plaintiff OWC.

158. Defendant Larry A. Rotenberg MD (“Dr. Rotenberg”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at 300 S 6th Ave. Reading PA 19611. He is affiliated with Defendant Tower Health.

159. Defendant Law Office of David K. Bifulco (“Bifulco Law Firm”) is a Pennsylvania professional entity of unknown corporate status with an office and place of business at 205 W. Broad St. Bethlehem PA 18018.

160. Defendant Lento Law Group PC (“Lento Law Firm”) is a Pennsylvania professional corporation with an office and place of business at 1500 Walnut St. Ste. 500 Philadelphia PA 19102.

161. Defendant Little Oley Tavern (“LOT”) is a commercial enterprise open to the public owned and operated by the Domenick defendants and located at 2068 Farmington Ave. Boyertown PA 19512.

162. Defendant Lorena Montecalvo (“Montecalvo”) is an adult citizen of the State of New Jersey residing at 867 Old White Horse Pike Waterford Works NJ 08089. She is the domestic partner of Defendant Joseph H. Kayati Jr. Each of them is sued as a tenant in the entirety.

163. Defendant Lyn B. Schoenfeld Esq. (Pa. Atty. No. 28170) (“Attorney Schoenfeld” or “Schoenfeld”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Schoenfeld Surkin Chupein and DeMis PC 25 W. 2nd St. Media PA 19063.

164. Defendant Manley Deas Kochalski LLC (“MDK Law Firm”) is an Ohio professional limited liability corporation with an office and place of business at 1515 Market St. #830 Philadelphia PA 19102.

165. Defendant Marc A. Lario and Associates (“Lario Law Firm”) is a New Jersey professional entity of unknown corporate form with an office and place of business at 89 N. Haddon Ave. Haddonfield NJ 08033. Defendant Marc A. Lario and Associates is liable in respondeat superior for the tortious, negligent, grossly negligent and/or criminal conduct of Defendant Mark A. Lario Esq.

166. Defendant Marc A. Lario Esq. (NJ Atty. No. 037191984) (“Administrator Lario” or “Lario”) is an adult citizen of the State of New Jersey with an office and place of business at Defendant Marc A. Lario and Associates 89 N. Haddon Ave. Haddonfield NJ 08033. Lario is the administrator of Defendant Estate of Joselyn C. Kayati.

167. Defendant Margolis Edelstein et al. (“Margolis Edelstein Law Firm”) is a Pennsylvania professional entity of unknown corporate form with an office and place of business at 170 S. Independence Mall W. STE 400E Philadelphia PA 19106.

168. Defendant Marilu Burgos (“Burgos”) is an adult citizen of the State of New Jersey with an office and place of business at Defendant County of Camden 101 S. 5th St. 6th Flr. Camden NJ 08103. She is the secretary to Defendant Sherri L. Schweitzer JSC.

169. Defendant Mark F. Gilson Esq. (Pa. Atty. No. 46400) (“DC Gilson” or “Gilson”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Disciplinary Board of the Supreme Court of Pennsylvania 1601 Market St. STE 3320 Philadelphia PA 19103. 

170. Defendant Marshall Dennehey PC (“Marshall Dennehey Law Firm”) is a Pennsylvania professional corporation with an office and place of business at 2000 Market St. Ste. 2300 Philadelphia PA 19103.

171. Defendant Mary T. Johnson JCCP (Pa. Atty. No. 72824) (“Judge Johnson” or “Johnson”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant County of Berks 633 Court St. Reading PA 19601. Defendant Mary T. Johnson JCCP is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of Defendants Tina M. Boyd JCCP, James E. Gavin JCCP, John B. Nevius JCCP, and *** (“Johnson Defendants”).

172. Defendant Matthew M. Graves Esq. (DC Atty. No. 481052) (“US Attorney Graves” or “Graves”) is an adult citizen of Washington DC with an office and place of business at Defendant United States 601 D Street NW Washington DC 20004. Defendant Matthew M. Graves Esq. is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of J. Doe Wash. DC ADA 1 and any additional non-party subordinates (“Graves Defendants”).

173. Defendant Matthew Truscott PSP (“Trooper Truscott” or “Truscott”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Pennsylvania State Police 600 Kenhorst Blvd. Reading PA 19611-1700. 

174. Defendant Meeting Ground Board of Directors (“Meeting Ground Board”) is the board of directors of Defendant Meeting Ground with an office and place of business at Defendant Meeting Ground 168 W. Main St. Elkton MD 21921. 

175. Defendant Meeting Ground d/b/a Cecil County Men’s Shelter (“Meeting Ground”) is a Maryland 501(c)(3) entity doing business as the “Cecil County Men’s Shelter” with an office and place of business at 168 W. Main St. Elkton MD 21921.

176. Defendant Meredith H. Wooters Esq. (Pa. Atty. No. 307207) (“Attorney Wooters” or “Wooters”) is an attorney of the Commonwealth of Pennsylvania with an office and place of business at Defendant Manley Deas Kochalski LLC 1515 Market St. #830 Philadelphia PA 19102.

177. Defendant Merrick B. Garland Esq. (DC Atty. No. 290759) (“Garland”) is an adult citizen of the District of Columbia with (at all relevant times) an office and place of business at Defendant United States 333 Constitution Ave. NW #3836 Washington DC 20001. Defendant Garland is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of Defendant Matthew M. Graves Esq. and his subordinates (“Garland Defendants”).

178. Defendant  Michael A. Chagares USJ (NJ Atty. No. 015581987) (“Judge Chagares” or “Chagares”) is an adult citizen of the State of New Jersey and has been the chief judge of the United States Court of Appeals for the Third Circuit since 2020, having been appointed by George W. Bush in 2006. Defendant Chagares is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of the following Elizabeth T. Hey USMJ, John M. Gallagher USDJ, Judges of the US Court of Appeals for the Third Circuit, Karen S. Marston USDJ and/or their subordinates (“Chagares Defendants”).

179. Defendant Michael Heimall FACHE FACHE (“Director Heimall” or “Heimall”) is an adult citizen of the District of Columbia with an office and place of business at Defendant Veterans Affairs Medical Center Washington District of Columbia 50 Irving St NW Washington DC 20422.

180. Defendant Miller Law Firm PC (“Miller Law Firm”) is a Pennsylvania professional corporation with an office and place of business at 718 Poplar St. STE I Lebanon PA 17042.

181. Defendant Myles B. Matteson Esq. (Pa. Atty. No. 323787) (“ADA Matteson” or “Matteson”) is an adult citizen of the State of New Hampshire who at all relevant times was an agent and employee of Defendant Chester County Office of the District Attorney 201 W. Market St. West Chester PA 19380.

182. Defendant Nathan M. Schenker Esq. (Pa. Atty. No. 40211) (“PD Schenker” or “Schenker”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant County of Chester 201 W. Market St. West Chester PA 19380.

183. Defendant Nusrat J. Love JCCP (Pa. Atty. No. 81907) (“Judge Love” or “Love”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant County of Delaware 201 W. Front St. Media PA 19063.

184. Defendant Pamela Mathias (“Detective Mathias” or “Mathias”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant County of Berks 633 Court St. Reading PA 19601.

185. Defendant Paul C. Neumann DO (“Dr. Neumann” or “Neumann”) is an adult citizen of the state of North Carolina with an office and place of business at 113 Virginia Rd. Edenton NC 27932.

186. Defendant Paul S. Peters Esq. (Pa. Atty. No. 87421) (“Attorney Peters” or “Peters”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant The Peters Firm PLLC PO Box 11227 Elkins Park PA 19027.

187. Defendant Pennsylvania Department of Human Services (“Pa. DHS”) is an agency/subordinate department of Defendant Commonwealth of Pennsylvania with an office or place of business at 625 Forster St. Harrisburg PA 17120.

188. Defendant Pennsylvania State Police (“Pa. State Police”)  is an agency/subsidiary of Defendant Commonwealth of Pennsylvania with an office and place of business at 1800 Elmerton Ave. Harrisburg PA 17110.

189. Defendant Pier N. Hess Esq. (Pa. Atty. No. 209415) (“DA Hess” or “Hess”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Lebanon County 400 S. 8th St. Lebanon PA 17042. Defendant Pier N. Hess Esq. is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of Defendant Todd Hirsch and/or their subordinates (“Hess Defendants”).

190. Defendant Potts Shoemaker & Grossman LLC (“PSG Law Firm”) is a Pennsylvania professional limited liability corporation/company with an office and place of business at 138-140 W. Gay St. West Chester PA 19380.

191. Defendant PrimeCare Medical Inc. (“PrimeCare”) is a Pennsylvania corporation with an office and place of business at 3940 Locust Ln. Harrisburg PA 17109. Defendant PrimeCare Medical Inc. is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of Defendant Jesse T. Kirsch.

192. Defendant Prince of Darkness a/k/a “Lucifer,” “Beelzebub,” “Mephistopheles,” “Abaddon,” “Apollyon,” “Belial,” “Mammon,” “Azazel,” “Iblis,” and/or “Mara” (“Satan”), is Defendants’ Lord and Savior, with an office and place of business at 2754 N. High St. Columbus OH, and is sued herein in respondeat superior for those Defendants’ earthly evil conduct, supra and infra. Service will be effectuated upon Satan by way of his defendant minions, so that proper jurisdiction may be had, contra United States ex rel. Mayo v. Satan and his Staff, 54 F.R.D. 282 (W.D. Pa. 1971). Defendant Prince of Darkness is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of the defendants and their subordinates (“Defendants” or “turds”).

193. Defendant Ralph D. Robinson Esq. (DC Atty. No. 44197) (“PD Robinson” or “Robinson”) is an adult citizen of the State of Virginia with an office and place of business at 8160 Skelton Circle Falls Church VA 22042.

194. Defendant Regina Armitage MDJ (“MDJ Armitage” or “Armitage”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at MDC 07-2-08 962 Town Center New Britain PA 18901. 

195. Defendant Richard E. Lombardi Esq. (Pa. Atty. No. 54293) (“Master Lombardi” or “Lombardi”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant County of Chester 201 W. Market St. West Chester PA 19380.

196. Defendant Richard Raiders Esq. (Pa. Atty. No. 314857) (“Attorney Raiders” or “Raiders”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Miller Law Firm PC 1150 Chestnut St. Lebanon PA 17042.

197. Defendant Robert Evanchick PSP (“Trooper Evanchick” or “Evanchick”)  is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business (for all relevant times) at Defendant Commonwealth of Pennsylvania 1800 Elmerton Ave. Harrisburg PA 17110.

198. Defendant Robert Henning Jr. (“Officer Henning” or “Henning”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Borough of Cleona 140 W. Walnut St. Cleona PA 17042.

199. Defendant Robert J. Krandel Esq. (Pa. Atty. No. 89485) (“AOPC Attorney Krandel” or “Krandel”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Administrative Office of the Pennsylvania Courts 1515 Market St. STE 1414 Philadelphia PA 19102.

200. Defendant Robert S. Feeman Esq. (Pa. Atty. No. 80052) (“Attorney Feeman” or “Feeman”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Feeman Law Offices 815 Cumberland St #200 Lebanon PA 17042.

201. Defendant Robin Kelly (“Director Kelly” or “Kelly”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant County of Chester 201 W. Market St. West Chester PA 19380.

202. Defendant Rochelle B. Grossman Esq. (Pa. Atty. No. 63172) (“Attorney Grossman” or “Grossman”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Potts Shoemaker & Grossman LLC 109 E. Evans St. STE 207 The Washington Building West Chester, PA 19380.

203. Defendant Roger Metzgar (“Metzgar”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Firefly Legal Inc. 19150 S. 88th Ave. Mokena IL 60448.

204. Defendant Ronald L. Davis (“Director Davis” or “Davis”) is an adult citizen of Washington DC with an office and place of business at Defendant United States Marshals Service 50 Irving St NW Washington DC 20422. Defendant Ronald L. Davis  is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of Defendants J. Does US Marshals 1-5 and United States Marshal Service (“Davis Defendants”).

205. Defendant Ryan M. Foltz (“Officer Foltz” or “Foltz”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Township of Douglass 1068 Douglass Dr. Boyertown PA 19512.

206. Defendant Sandra L. Fegley MDJ (“MDJ Fegley” or “Fegley”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at 6112 Perkiomen Ave. Birdsboro PA 19508. Defendant Sandra L. Fegley MDJ is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of Defendants J. Does MDC 23-2-03 1-5 (“Fegley Defendants”).

207. Defendant Schoenfeld Surkin Chupein & DeMis PC (“SSCD Law Firm”) is a Pennsylvania professional corporation with an office and place of business at 25 W. 2nd St. Media PA 19063. 

208. Defendant Scott Kassel PhD (“Scott Kassel”) is an adult citizen of the Commonwealth of Pennsylvania residing at 819 Pleasant Hill Rd. Wallingford PA 19086. He is married to Defendant Dora L. Kassel.

209. Defendant Scott S. Lisgar Esq. (Pa. Atty. No. 83099) (“Attorney Lisgar” or “Lisgar”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Keller Lisgar & Williams LLP 18 W. Front St. Media PA 19063. 

210. Defendant Sherri L. Schweitzer JSC (NJ Atty. No. 016051995) (“Judge Schweitzer” or “Schweitzer”) is an adult citizen of the State of New Jersey with an office and place of business at Defendant County of Camden 101 S. 5th St. 6th Flr. Camden NJ 08103.

211. Defendant Shirley Hickman (“SW Hickman” or “Hickman”)  is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Veterans Affairs Medical Center Coatesville PA 1400 Blackhorse Hill Rd. Coatesville PA 19320.

212. Defendant Society of Jesus (“The Jesuits”) is an agency/subordinate department of Defendant Holy Roman Catholic and Apostolic Church with an office and place of business at Borgo Santo Spirito 400193 Roma RM Italy.

213. Defendant Starbucks Corporation (“Starbucks”) is a State of Washington corporation with a headquarters at 2401 Utah Ave. S. STE 800 Seattle WA 98134-1435.

214. Defendant State of Delaware (“Delaware”) is a state of Defendant United States composed of three branches as established by the Delaware Constitution (“Del. Const.”) with an office and place of business at 820 N. French St. Wilmington DE 19801. Defendant State of Delaware is liable in respondeat superior for the tortious, negligent, grossly negligent and/or criminal conduct of Defendant The Rockford Center, or in the alternative, is sued as a necessary party in qui tam along with same, who upon information and belief, was the recipient of state funds disposed of fraudulently in unlawfully restraining/imprisoning/kidnapping Plaintiff Connelly.

215. Defendant State of Maryland (“Maryland”) is a state of Defendant United States composed of three branches as established by the Maryland Constitution (“Md. Const.”) with an office and place of business at 200 St. Paul Place Baltimore MD 21202. Defendant State of Maryland is liable in respondeat superior for the tortious, negligent, grossly negligent and/or criminal conduct of Defendant County of Cecil MD, or in the alternative, is sued as a necessary party in qui tam along with same, who upon information and belief, was the recipient of state funds disposed of fraudulently in the treatment of Plaintiff Connelly by its recipients.

216. Defendant State of New Jersey (“New Jersey”) is a state of Defendant United States composed of three branches as established by the New Jersey Constitution (“NJ Const.”) with an office and place of business at 25 Market St. Trenton NJ 08611. Defendant State of New Jersey is liable in respondeat superior for the tortious, negligent, grossly negligent and/or criminal conduct of defendants Charles G. Resnick Esq., County of Camden NJ, Marc A. Lario and Associates, Sherri L. Schweitzer JSC and Marilu Burgos (“State of NJ Defendants”).

217. Defendant Steven DW Miller Esq. (Pa. Atty. No. 317850) (“Attorney Miller” or “Miller”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Miller Law Firm PC 718 Poplar St. STE I Lebanon PA 17042.

218. Defendant Steven M. Chieffo MDJ (“MDJ Chieffo” or “Chieffo”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Commonwealth of Pennsylvania MDC 23-3-03 PO Box 18 590 Oley Rd. Oley PA 19547.

219. Defendant Surgical Institute of Reading (“SIR”) is a subsidiary of Dallas-based Tenet Healthcare with an office and place of business at 2752 Century Blvd. Wyomissing PA 19610.

220. Defendant Suzie Marker (“Administrator Marker” or “Marker”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant County of Chester 201 W. Market St. West Chester PA 19380.

221. Defendant The Cigna Group (“Cigna”), is a Delaware corporation with a headquarters at 900 Cottage Grove Road Bloomfield CT 06002. 

222. Defendant The Hartford Financial Services Group Inc. (“Hartford”) is a Connecticut corporation with an office and place of business at 690 Asylum Ave Hartford CT 06106. 

223. Defendant The Money Source Inc. (“Money Source”) is an Arizona corporation with an office and place of business at 1800 Walt Whitman Rd. # 130 Melville NY 11747.

224. Defendant The Peters Firm PLLC (“Peters Firm”) is a Pennsylvania professional limited liability corporation/company with a mailing address at PO Box 11227 Elkins Park PA 19027.

225. Defendant The Rockford Center (“Rockford Center”) is a Delaware corporation with an office and place of business at 100 Rockford Dr. Newark DE 19713.

226. Defendant Thomas J. Farrell Esq. (Pa. Atty. No. PA 48976) (“CDC Farrell” or “Farrell”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Office of Disciplinary Counsel 601 Commonwealth Ave. STE 2700 PO Box 62485 Harrisburg PA 17106-2485.

227. Defendant Tiffany A. Shoemaker Esq. (Pa. Atty. No. 83217) (“Attorney Shoemaker” or “Shoemaker”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Potts Shoemaker & Grossman LLC 109 E. Evans St. STE 207 The Washington Building West Chester, PA 19380.

228. Defendant Tina M. Boyd JCCP (Pa. Atty. No. 83499) (“Judge Boyd” or “Tina Boyd”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant County of Berks 633 Court St. Reading PA 19601.

229. Defendant Todd Hirsch (“Detective Hirsch” or “Hirsch”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant County of Lebanon 400 S. 8th St. Lebanon PA 17042.

230. Defendant Tony House (“House”) is an adult citizen of the State of Maryland with an office and place of business at Defendant Meeting Ground 168 W. Main St. Elkton MD 21921. 

231. Defendant Tower Health (“Tower”) is a Pennsylvania 501(c)(3) entity with an office and place of business at 420 S. 5th Ave. West Reading PA 19611.

232. Defendant Town of Elkton (“Elkton”) is the seat of Defendant County of Cecil and is governed by an elected mayor and four commissioners (with a hired administrator) and an office and place of business at 100 Railroad Ave. Elkton MD 21921.

233. Defendant Township of Alsace (“Alsace Twp.”) is a township of Defendant County of Berks with an office and place of business at 65 Woodside Ave. Temple PA 19560.

234. Defendant Township of Amity (“Amity Twp.”) is a township of Defendant County of Berks with an office and place of business at 2004 Weavertown Rd. Douglassville PA 19518. Defendant Township of Amity PA is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of Defendants J. Does Amity Twp. PD 1-5 and/or their subordinates.

235. Defendant Township of Douglass (“Douglass Twp.”) is a township of Defendant County of Berks with an office and place of business at 1068 Douglass Dr. Boyertown PA 19512. Defendant Township of Douglass PA is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of Defendant Douglass Twp. PD and/or its subordinates.

236. Defendant Township of Lower Alsace PA (“Lower Alsace Twp.”) is a township of Defendant County of Berks with an office and place of business at 1200 Carsonia Ave. Reading PA 19606. 

237. Defendant Tracy L. Christman Esq. (Pa. Atty. No. 314332) (“Master Christman” or “Christman”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant County of Chester 201 W. Market St. West Chester PA 19380.

238. Defendant TTEC Holdings Inc. (“TTEC”) is a Colorado corporation with an office and place of business at 6312 S. Fiddlers Green Cir. STE 100N Greenwood Village CO 80111.

239. Defendant United Parcel Service Inc. (“UPS”) is an American corporation of unknown form with a headquarters at 55 Glenlake Parkway NE Atlanta GA 30328.

240. Defendant United States Marshal Service (“USMS”) is an agency/subsidiary of Defendant United States of America with an office and place of business at  50 Irving St NW Washington DC 20422.

241. Defendant United States of America (“United States” or “U.S.” or “US”) is a constitutional federal republic. “Constitutional” refers to the fact that government in the United States is based on a Constitution (“U.S. Const.”) which is the supreme law of the United States. The Constitution not only provides the framework for how the federal and state governments are structured but also places significant limits on their powers. “Federal” means that there is both a national government and governments of the fifty states. A “republic” is a form of government in which the people hold power but elect representatives to exercise that power. The United States has an office and place of business at 950 Pennsylvania Avenue NW Washington DC 20530-0001. Defendant United States is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of Defendants Commonwealth of Pennsylvania, Joseph Robinette Biden Jr., Michael A. Chagares USJ, State of Delaware, State of Maryland, State of New Jersey, and Washington District of Columbia (“United States Defendants”) or in the alternative, is sued as a necessary party in qui tam along with same, who upon information and belief, was the recipient of federal funds disposed of fraudulently.

242. Defendant Valerie A. Arkoosh MD MPH (“Secretary Arkoosh” or “Arkoosh”)  is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Department of Human Services 625 Forster St. Harrisburg PA 17120.

243. Defendant Vamsee Potluri (“Director Potluri”) is an adult citizen of the State of Delaware with an office and place of business at Defendant Veterans Affairs Medical Center Wilmington DE 1601 Kirkwood Hwy. Wilmington DE 19805.

244. Defendant Veterans Affairs Medical Center Coatesville PA (“VAMC Coatesville”) is an agency/subsidiary of Defendant Department of Veterans Affairs with an office and place of business at 1400 Blackhorse Hill Rd. Coatesville PA 19320.

245. Defendant Veterans Affairs Medical Center Lebanon PA (“VAMC Lebanon”) is an agency/subsidiary of Defendant Department of Veterans Affairs with an office and place of business at 1700 S. Lincoln Ave. Lebanon PA 17042.

246. Defendant Veterans Affairs Medical Center Perry Point MD (“VAMC Perry Point”) is an agency/subsidiary of Defendant Department of Veterans Affairs with an office and place of business at 361 Boiler House Rd. Perry Point MD 21902-1103.

247. Defendant Veterans Affairs Medical Center Washington DC (“VAMC Washington DC”) is an agency/subordinate department of Defendant Department of Veterans Affairs with an office and place of business at 50 Irving St. NW Washington DC 20422.

248. Defendant Veterans Affairs Medical Center Wilmington DE (“VAMC Wilmington”) is an agency/subordinate department of Defendant Department of Veterans Affairs with an office and place of business at 1601 Kirkwood Hwy. Wilmington DE 19805.

249. Defendant Veterans on the Rise (“VOTR”) is a Washington District of Columbia 501(c)(3) entity with an office and place of business at 5002 Sheriff Rd. NE Washington DC 20019. Defendant Veterans on the Rise is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of Defendants J. Does VOTR 1-5, Kavell Whitehead  (“VOTR Defendants”).

250. Defendant Washington DC Metro. PD (“DC Metro PD”), is an agency/subsidiary of Defendant Washington District of Columbia with an office and place of business at 300 Indiana Ave. NW Washington DC 20001. Defendant Washington DC Metro. PD is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of Defendants J. Does Wash. DC Metro. PD 1-20.

251. Defendant Washington District of Columbia (“Washington DC” or “District of Columbia”) is a federal district under the exclusive jurisdiction of the Congress of Defendant United States of America with an office and place of business at 441 4th Street NW Washington DC 20001. Defendant Washington District of Columbia is liable in respondeat superior for the aforesaid tortious, negligent, grossly negligent and/or criminal conduct of Defendants Anthony C. Epstein JDC, Ralph D. Robinson Esq., Veterans on the Rise, Washington DC Metro. PD (“District of Columbia Defendants”). 

252. Defendant William D. Longo Esq. (Pa. Atty. No. 59828) (“Attorney Longo” or “Mongo” “Longo”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Margolis Edelstein 170 S. Independence Mall W. STE 400E Philadelphia PA 19106.

253. Defendant William L. Goldman Esq. (Pa. Atty. No. 21201) (“Attorney Goldman” or “Goldman”) is an adult citizen of the Commonwealth of Pennsylvania with an office and place of business at Defendant Goldman Law Offices 90 E. State St. Doylestown PA 18901.

254. Defendant Wyndham Hotels & Resorts Inc. (“Wyndham Hotels”) is a Delaware corporation doing business as “Days Inn by Wyndham” and at all relevant times owned and operated a commercial property by that name at 625 Quentin Road Lebanon PA 17042.

PRELIMINARY DEFINITIONS 

(and stuff) 

1. “Mail fraud” is the federal crime codified at 18 U.S.C. § 1341.

2. “Wire fraud” is the federal crime codified at 18 U.S.C. § 1343.

3. “Honest services fraud” is mail or wire fraud, supra, as defined/described by 18 U.S.C. § 1343. 

4. The Trafficking Victims Protection Reauthorization Act of 2003 (“TVPRA 2003”)  22 U.S.C. § 7101 et seq. added “human trafficking” (both sex and labor) to the list of predicate offenses for RICO, and allowed victims to pursue monetary damages from their traffickers to cover compensation for injuries, pain, and suffering, recovery of earnings they were denied due to trafficking, and costs associated with medical care, therapy, and other forms of support needed to recover from trafficking.

5. In Edmonson v. Leesville Concrete Co., 500 U.S. 614, 111 S. Ct. 2077 (1991), the Court stated that “[a]lthough the conduct of private parties lies beyond the Constitution's scope in most instances, governmental authority may dominate an activity to such an extent that its participants must be deemed to act with the authority of the government and, as a result, be subject to constitutional constraints.” Ibid.

STATEMENT OF FACTS AND PROCEDURAL HISTORY

1. On Friday, August 2, 2024, Plaintiff was unlawfully evicted without lawful basis from his residence at 168 W. Main St. Elkton Maryland (“Cecil County Men’s Shelter”) which upon information and belief, through Defendant Meeting Ground, receives county, state, and federal funding, by and through an illegal conspiracy between Defendant United States, to wit, Defendants Reed and Cook, the “Meeting Ground” defendants, principally Defendant House, and the Elkton Police Department.

2. The unlawful basis for the eviction was that Plaintiff Connelly tested positive for marijuana, which is legal in Maryland (and which Connelly used to treat his PTSD and TBI after the VA completely failed him), and Plaintiff Connelly’s demand that Defendant Reed put in writing the basis for her and Defendant Cook’s continual and repeated harassment of Connelly (which request was never met).

3. The eviction caused Plaintiff Connelly to experience a severe aggravation of his chronic post traumatic stress disorder (PTSD) status-post traumatic brain injuries (TBI) dating back to 1995, when Plaintiff Connelly was on active duty with the United States Navy in South Africa working with the South African Navy, and contracted meningitis which developed into a hydrocephalus.

4. He sought treatment at Defendant Veterans Affairs Medical Center Wilmington DE for the PTSD aggravation.

5. When Plaintiff Connelly was told that he would be sent to Defendant Veterans Affairs Medical Center Coatesville PA, he gladly signed a voluntary admission under Pennsylvania Statutes Title 50 P.S. Mental Health § 7201 (50 Pa. Stat. § 7201 et seq.).

6. Connelly’s eight-year-old daughter, Plaintiff OWC, upon information and belief, resides in Chester County, Pennsylvania, and Plaintiff Connelly had been unsuccessfully seeking residential PTSD treatment from the Defendant Dept. of Veterans Affairs (“VA”) since 2022, when he was assaulted by Defendant Pennsylvania State Trooper James Green on his front porch in front of his then-partner, Emma Dean and was concussed thereby. Green’s assault opened a ‘Pandora’s Box’ of trauma in Plaintiff Connelly dating back to his childhood and including events experienced during his active military service.

7. After many, many hours, which allowed Plaintiff Connelly an opportunity to meditate and thereby self-treat the PTSD aggravation, and when there still was no word that he was even accepted at Coatesville (to which he had previously applied but been refused because his PTSD “was not the right kind,” see Exhibit PC-*** (mhv_CONNELLY_20240820_1906_redacted), and after being informed that he would have to leave his car in Delaware, even though he was perfectly safe to drive, Connelly asked to be given his car keys and released. Repeatedly.

8. Rather than release him as he had requested multiple times, Connelly was transported by the local police to Defendant The Rockford Center, where he developed two abscessed teeth.

9. Plaintiff Connelly was at no time seen by a mental health professional while at Defendant Veterans Affairs Medical Center Wilmington DE. A female social worker signed the commitment paperwork—paperwork that she refused to allow Plaintiff Connelly to examine.

10. Connelly was refused treatment for the abscessed teeth and/or release from Rockford Center for three days, suffering severe pain and mental anguish thereby. 

11. Eventually, Plaintiff Connelly broke the more painful of the two teeth out himself, leaving the root (the other one eventually broke as well).

12. The aforesaid involuntary commitment by the VAMC Wilmington Defendants constituted a felonious involuntary restraint/kidnapping pursuant to Delaware's Criminal Code, Title 11, Chapter 261, Section 786 (Del. Code tit. 11 §§ 782, 783, and/or 786), and a predicate act under RICO because (1) the offense substantially conforms to the prevailing definition of kidnapping; (2) does not use the same titles as the listed predicate offenses; (3) was committed in connection with an enterprise, to wit, Defendant United States, and the RICO defendants herein have committed at least two predicate offenses within a 10-year period.

13. Immediately prior to his aforesaid illegal involuntary commitment at Defendant Rockford Center, Plaintiff Connelly filed claims in Connelly v. House, et al., Civ. Action No. C-07-CV-24-423 (Cecil Md. 2024), and served Defendant Elkton Police Department and the Meeting Ground Defendants via Defendant Angelo Martinez in a raging thunderstorm. Defendant Martinez threw the Complaint into the gutter, recording the event on video with his cell phone.

DEFENDANT CHESTER COUNTY PENNSYLVANIA et al.

1. On or about July 27, 2020, Defendant Larissa Connelly at Defendant Potts’ direction, contacted  Defendant Pennsylvania State Police (“PSP”) Officer Brian J. McCabe, alleging that Plaintiff Connelly had sent her text messages that were ‘harassing.’ 

2. On September 9, 2021, Defendant McCabe charged Plaintiff Connelly with three counts of harassment under 18 Pa. C.S.A. § 2709 (a). The charges were filed the day prior to the hearing on Defendants Potts’ and Larissa Connelly’s frivolous petition for expedited relief, infra, and forty-four days after Defendant McCabe initiated his ‘investigation’.

3. Defendant Larissa Connelly, at Defendant Potts’ direction, had applied for these criminal charges knowing that Plaintiff Connelly was in the Accelerated Rehabilitative Disposition (ARD) program in Berks County for wholly-unrelated charges from more than a year prior stemming from the ‘bar fight’ incident, supra.

4. Defendant Potts and Connelly were fully-aware that Connelly upon completion of ARD would have had a completely clean criminal record, but that additional charges, warranted or otherwise, would have placed Plaintiff Connelly in danger of being removed from the program and the original charges reimposed.

5. Defendants Potts and Connelly were also aware, or should have been aware, that Plaintiff Connelly had completed all the terms of his ARD ‘probation’ and had asked his then attorney Defendant Paul S. Peters, Esq., to file a motion to terminate Connelly’s ARD, as Plaintiff Connelly had (1) undergone a psychological evaluation with the Veterans’ Administration (“VA”); (2) completed an anger management program with the VA, wherein no further treatment was recommended; (3) had paid all of his court fines and costs; (4) had completed a substance abuse evaluation, again with the VA, wherein no treatment was recommended; and (5) had completed more than the required forty hours of community service by picking up trash and recycling along the roads of Berks County, Pennsylvania.

6. Defendants Potts and Connelly were also aware, or should have been aware, that Plaintiff Connelly was expected to go from a contract employee to a regular employee at the end of 2020 with his employer, Express Scripts, a major online pharmacy, and would need to undergo a background check to effectuate that transition.

7. Thus, the criminal charges were solicited by Defendant Larissa Connelly at Defendant Potts’ direction, solely to trigger termination of Plaintiff Connelly’s ARD status and thereby destroy Plaintiff Connelly’s ability to gain and/or maintain employment, and to thereby alienate him from Plaintiff, OWC, and to handicap him in his ability to litigate OWC’s custody.

8. As Defendants Potts and Connelly hoped, on October 12, 2020, Plaintiff Connelly lost his $100,000.00 per annum position with Express Scripts due to the frivolous harassment charges filed by Defendants Larissa Connelly, Potts, and McCabe.

9. Plaintiff Connelly, in anticipation of losing his job due to Defendant Potts’, Connelly’s and McCabe’s machinations, had applied to online retailer Amazon.com for $15.00 per hour warehouse work and received an offer to hire starting October 21, 2020, contingent upon a background check.

10. On October 27, 2020, Plaintiff Connelly received an email from ‘Accurate Background’ stating:

As you know, Amazon.com, Inc. or its subsidiaries or affiliates ("Amazon") procured a consumer report, also known as a background check on you. We now write to advise you that Amazon is unable to make a decision regarding your eligibility for employment or continued employment at this time. The reason for this is the existence of a pending criminal charge (or charges) against you. Once this matter has been resolved, we invite you to re-apply at Amazon.

11. Plaintiff Connelly received similar rejections from defendant employers Cigna, UPS, Ashley Furniture, and TTEC Holdings. He filed EEOC charges against these employers for improper discrimination on the basis of mere criminal allegations (without the requisite investigation/determination), which were denied (Connelly was told by EEOC that had he been “black,” he would have had claims), and then writs of summons in Defendant Berks County, tolling the statute of limitations, and permitting Plaintiff Connelly to pursue his claims against these discriminatory employers in this action (Plaintiff Connelly reached a settlement with Amazon.com, and they are thus not a party herein).

12. Plaintiff Connelly would also later bring an EEOC discrimination charge against Defendant, Starbucks Corporation. See, e.g., Exhibit PC-*** (💼 EEOC connelly v. starbucks (2024)).

13. As a direct and proximate result of Defendants Connelly, Potts, and  McCabe’s machinations (and later Defendant Ryan and her defendant subordinates’), Plaintiff Connelly had no choice but to  drive for www.delivery.com, a delivery service, making two dollars per delivery plus tips on a 1099 because he could not obtain W-2 employment while the frivolous harassment charges were pending.

14. As a direct and proximate result of Defendants Connelly, Potts, and  McCabe’s machinations (and later Defendant Ryan’s and her defendant subordinates’), Plaintiff Connelly was forced to withdraw, mid-semester, from his bachelor’s program in Mathematics at the University of Illinois at Springfield, causing him to be obligated for tuition fees unnecessarily.

15. As a direct and proximate result of Defendant Connelly, Potts, and  McCabe’s machinations (and later Defendant Ryan and her defendant subordinates’), Plaintiff Connelly was also forced to declare Chapter 7 bankruptcy on February 10, 2021. See In re Connelly, Jr., Bankruptcy Pet. No. 4:2021bk10334-pmm.

16. At the time that the frivolous criminal charges were solicited from  Defendant McCabe by Defendant Larissa Connelly at Defendant Potts’ direction, it was only the most recent event in a clear history of abuse of civil and criminal process, attempted character assassination, and civil and criminal fraud perpetrated by Potts and Connelly and their various judicial enablers, all of which was calculated to unfairly prejudice Plaintiff Connelly in his custody case, and alienate him from minor plaintiff OWC.

17. On August 31, 2020, Defendant Potts on behalf of Defendant Larissa Connelly filed an application for expedited relief. This application was again without basis in fact or law, and furthermore was not ‘emergent’ and should not have qualified for expedited relief.

18. Connelly was not aware that there were pending criminal charges until his then-attorney, Defendant Paul S. Peters, Esq., shared Defendant Larissa Connelly’s application for expedited relief with him.

19. On September 9, 2020, the day after Plaintiff Connelly was criminally charged with harassment, the expedited petition was purportedly ‘heard’ by corrupt Chester County Hearing Officer Defendant Richard E. Lombardi. There was no competent evidence presented at the hearing by Defendants Potts and Connelly, but all of it was nonetheless considered by Defendant Lombardi over Plaintiff Connelly’s attorney, Defendant Paul S. Peters, Esquire’s objection.

20. Most significantly, Defendant Lombardi made no findings of facts or conclusions of law. Connelly v. Connelly, 2341 EDA 2020 (Pa. Cmmw. Ct. Oct. 15, 2021).

21. The extra-jurisdictional, illegal, and void recommended order solicited from Lombardi by Potts and Defendant Larissa Connelly was transmitted to Plaintiff Connelly’s attorney via email, and upon information and belief, was uploaded to the Chester County Prothonotary and Family Court servers via internet protocols, all in interstate commerce. See, e.g., 109. RICO Charges, Justice.gov (2015) (last visited Jul 18, 2024). 

22. Defendant Katherine B.L. Platt JCCP ‘rubber-stamped’ the order without review, and no additional findings of fact or conclusions of law in abject violation of Pennsylvania law. Connelly v. Connelly, 2341 EDA 2020 (Pa. Cmmw. Ct. Oct. 15, 2021).

23. This act constituted a violation of 18 U.S.C. § 1346 (honest services fraud) (18 U.S.C. § 1346 defines the term “scheme or artifice to defraud,” as used in the general statutes prohibiting use of the mails or wires to commit fraud, to include a scheme or artifice to deprive another of the intangible right of honest services), and a predicate act under 18 U.S.C. §§ 1961-68 (RICO).

24. Because the order was executed by Defendant Platt without review and in violation of Plaintiff Connelly’s rights to due process of law, supra, it must be considered extra-judicial (and ‘administrative’ at best), subjecting Defendant Platt to criminal and civil liability for her illegal acts.

25. The ‘Christman’ hearing of July 2, 2020 and resultant ‘rubber-stamp’ order entered by Defendant Judge Sondergaard (“July Custody Order”) were also illegal according to the same arguments made against the ‘Lombardi’ conference and the September Custody Order, supra, with the added illegality that Plaintiff Connelly was not even present for that ‘hearing,’ having calendared the correct day but the incorrect month. 

26. The same federal jurisdictional ‘hooks’ apply to the criminal acts of Defendants Christman, Potts and Sondergard with respect to the Christman hearing and July Custody Order. See, e.g., 109. RICO Charges, Justice.gov (2015),  (last visited Jul 18, 2024). 

27. Defendant Judge Platt intentionally and unlawfully entered the September Custody Order where a conference was held and the parties had no agreement as to custody, no further hearing was scheduled, and no record was made, all in violation of 231 Pa. Code § 1915.4-2 and Plaintiff Connelly’s rights to due process and equal protection (as a male) under the Constitutions of the Commonwealth of Pennsylvania and the United States.

28. Moreover, assuming arguendo that the September 9, 2020 Lombardi proceeding was a ‘conference’ pursuant to 231 Pa. Code § 1915.4-2 (a), since the parties certainly did not agree and no subsequent hearing was scheduled, those proceedings were illegal under 231 Pa. Code § 1915.4-2 (a).

29. Similarly, if the September 9, 2020 Lombardi proceeding was a ‘hearing’ pursuant to 231 Pa. Code § 1915.4-2 (b), as no record was made, the proceedings and resultant recommendation and order were illegal pursuant to 231 Pa. Code § 1915.4-2 (b).

30. Furthermore, 231 Pa. Code § 1915.4-2 (b)(4) provides for a twenty day period for objections prior to the entry of the interim custody order. Here, the recommendation was issued on September 9, 2020, the day of the hearing (in fact, Plaintiff Connelly was on his way to pick up Plaintiff OWC for a dinner visit when he was turned away by Defendant Larissa Connelly based on the ‘supervised custody’ provision of the recommendation), and the resultant order was entered into the docket by Defendant Platt five days later, on September 14, 2020, in violation of 231 Pa. Code § 1915.4-2 (b)(4). See 231 Pa. Code § 1915.4-2 (b)(4).

31. This tort/crime rendered September 6, 2020 as the last day that Plaintiff Connelly was in physical contact with minor plaintiff OWC as of the date of this writing.

32. Moreover, like the July Custody Order, the September Custody Order was patently illegal and void ab initio because it did not include the language required by Chester County Local Rule of Court 1915.4.A (b)(2).

33. There was little to no competent evidence presented at the hearing by Defendant Larissa Connelly through Defendant Potts, but all of it was nonetheless considered by Defendant Lombardi over Defendant Paul Peters, Esquire’s objection.

34. Defendant Lombardi’s recommendation was, unsurprisingly, beyond the pale of rational, competent jurisprudence, and is per se evidence of collusion and conspiracy with Defendant Larissa Connelly and Potts.

35. In a now-familiar pattern, Defendants Potts and Connelly again received carte blanche, this time from Defendant Lombardi, who recommended a draconian order unsupported by facts or law. The most egregious of these terms was the limiting of Plaintiff Connelly’s parenting time to six hours on every other Saturday under supervised custody at Plaintiff Connelly’s cost (he could not afford it). Plaintiff Connelly was thus granted a measly twelve pay-per-view hours per month with his child, plaintiff OWC under a void, illegally-solicited order.

36. Significantly, the order also explicitly limited Plaintiff Connelly’s phone time with Plaintiff OWC to fifteen minutes per day. Again, Defendant Lombardi simply allowed Defendant Potts, his buddy, to place an order for her client’s relief a la carte, with no regard for the law or the competent evidence (if any).

37. This meant that Plaintiff, OWC could no longer visit her Father, Plaintiff Connelly at his home, where she then had her own room, 4 cats, 2 dogs, multiple toads, a worm farm and organic garden, and where she spent time with her brother, Plaintiff Thomas P. Connelly, III, and sister, minor plaintiff EMC, both of whom she adores, and whom, as noted above, Plaintiff Connelly had at that time every weekend by informal agreement with Plaintiff Connelly’s first wife, Defendant Dora L. Kassel.

38. Plaintiff’s former residence at 23 Petsch Road sat on four and one-half acres of woodland, one-third of a mile down a private drive, with immediate walking access to hiking and mountain-biking trails.

39. Before they were essentially kidnapped (hereinafter “court-napped” or “courtnapped”) by criminal attorneys, masters and judges in Chester County, Plaintiff Connelly and his children would enjoy campfires almost every weekend, watch movies on the ‘big screen’ (the family room wall via a projector), and Plaintiff Connelly was teaching his children archery and marksmanship on an air rifle.

40. Lombardi’s ‘recommendation’ (and Platt’s rubber-stamp) furthermore meant that Plaintiff OWC would be unable to continue her horseback riding lessons at the Corner House Farm, where she was learning to ride ‘Rusty’, nor could she continue with ‘Soccer Shots.’

41. Until the July and September custody ‘hearings’, OWC had attended these activities with Plaintiff Connelly every weekend. OWC and Plaintiff Connelly also enjoyed fishing, hiking around the local reservoir, painting, writing stories having toad races Mark Twain style, and visiting the Reading Museum, one of OWC’s favorite places, and where OWC met her first friend in the Reading area, whom she has not seen in four years due to Defendants Larissa Connelly’s, Potts’, Huffman’s, and others’ machinations.

42. Most significantly, Plaintiff Connelly, having lost his employment due to the frivolous harassment charges, could not afford the substantial fees for supervised visitation, and has not seen Plaintiff OWC in person since September 6, 2020, three days before the Lombardi ‘hearing’.

43. In addition to being based on incompetent evidence, Defendant Potts and Connelly’s expedited relief petition was replete with material factual errors and omissions in a calculated and deliberate attempt to unfairly prejudice Plaintiff Connelly.

44. For example, Defendant Potts represented to Defendant Lombardi that ‘SoberLink’ tests that were taken in full compliance with the order were 'missed' because the SoberLink system only operates on full hours whereas the order specified testing at 10:30 p.m.

45. It was wholly disingenuous and frankly criminally fraudulent for Defendant Potts to have made this argument because Plaintiff Connelly long before had requested that the SoberLink agreement be amended to accurately reflect the terms of the July 8, 2020, Order, and Defendants Potts and Connelly refused to respond.

46. Furthermore, missed, or positive tests during non-custodial periods were urged upon Defendant Lombardi by Defendant Potts as evidence that the emergent relief should be granted, which was wholly inappropriate.

47. A single positive test during Plaintiff Connelly’s custodial time inside the legal limit of .08 was offered by Defendant Potts and considered by Defendant Lombardi as evidence of intoxication at a prior time.

48. Potts argued on a relation-back theory that Plaintiff Connelly was legally intoxicated. This was wholly improper as Potts was not an expert in toxicology and could not properly give relation-back opinion testimony.

49. More importantly, there was no order in effect that prohibited intoxication, above the legal limit or otherwise, during Plaintiff Connelly’s custody periods or otherwise.

50. Indeed, there was no basis for the SoberLink requirement to begin with, as the July Custody Order was entered in Plaintiff Connelly’s absence and in clear violation of his due process rights and without his input, supra.

51. Nonetheless, Defendant Lombardi accepted this wholly incompetent evidence as the lynchpin of Defendant Larissa Connelly's claim for expedited relief, as if it were somehow a violation of an order of court.

52. Defendant Lombardi furthermore considered the affidavit of probable cause from Plaintiff Connelly’s then year-old ARD case, which had absolutely nothing to do with Defendant Larissa Connelly or Plaintiff OWC, but in fact occurred while Plaintiff Connelly was living away from home during the workweek to provide for OWC and Defendant Larissa Connelly, who, as noted, had refused to work, supra.

53. The criminal charges leveled against Plaintiff Connelly (most notably the affidavit of probable cause) considered by Defendant Lombardi were hearsay, out-of-court statements offered for the truth of the matter asserted to which no exception applied.

54. Moreover, they were mere allegations and of course only one side of the story. None of it was competent evidence but was maliciously proffered by Defendant Larissa Connelly through Defendant Potts and accepted by Defendant Lombardi in an illegal and collusive scheme to further truncate Plaintiff Connelly's parental rights, and to alienate him from Plaintiff OWC without basis.

55. The allegations against Plaintiff Connelly, which proceeded from the aforesaid ‘bar fight’ wherein Plaintiff Connelly was attacked by four male bar patrons after putting his arm around the waist of a woman he had met there that night, witness Lora Oherrick, and wherein Plaintiff Connelly’s ankle was broken in three places by the three police officers and/or four male bar patrons involved were falsely and maliciously characterized by Defendant Larissa Connelly through Defendant Potts (and considered by Defendant Lombardi), as an “attempted kidnapping.”

56. Connelly was not charged with attempted kidnapping, which is a felony. Rather, all the charges were misdemeanors that have since been dismissed and expunged, despite Defendant Potts’ and Defendant Larissa Connelly’s attempts to interfere. See Commonwealth v. Connelly, Crim. Action No. CP-06-CR-3185-2019 (Berks, Pa. 2019).

57. Furthermore, Defendant Larissa Connelly’s defamatory statements through Defendant Potts, most notably the attempted kidnapping accusation, represented clear violations 204 Pa. Code § 3.3 (a)(1), which prohibits a lawyer’s making “a false statement of material fact or law to a tribunal.” 204 Pa. Code § 3.3 (a)(1).

58. This tort/crime/defamation rendered September 6, 2020 as the last day that Plaintiff Connelly was in physical contact with Plaintiff OWC as of the date of this writing.

59. Defendant Potts’ false and malicious statements also represent a violation of 204 Pa. Code § 4.4 (a), which prohibits a lawyer’s using means “that have no substantial purpose other than to embarrass, delay, or burden a third person…” 204 Pa. Code § 4.4 (a).

60. Defendants Potts and Lombardi were/are ‘Facebook friends,’ e.g., EXHIBIT PC-*** (2020-12-26 FB lombardi↔potts), and they clearly colluded and conspired to manufacture a recommended order that was inconsistent with the competent evidence and applicable case law, was wholly prejudicial to Plaintiff Connelly, and was intended only to harass, vex, and abuse Plaintiff Connelly and to alienate him from Plaintiff OWC.

61. Lombardi’s corruption and incompetence are well-known by the litigants of Chester County, and not limited to Plaintiff Connelly’s matter. See, e.g., EXHIBIT PC-*** (Who Is Lombardi Chester County Family Court? Talk About Corrupt Custody Issues). He must be removed from public service and the practice of law for his disgusting, unethical, and illegal conduct.

62. Defendant Potts refused to produce the allegedly actionable messages sent from Plaintiff Connelly to Defendant Larissa Connelly at issue in the case but argued them orally to Defendant Lombardi anyway, an obvious ethical impropriety.

63. Plaintiff Connelly believes and alleges that Defendant Potts, who touted her experience as a former Chester County Assistant District Attorney on her now defunct firm’s website, and knowing that she had directed Defendant Larissa Connelly (and probably Defendant PSP Trooper McCabe, infra), to bring the frivolous harassment charges based upon the same messages, did not want Plaintiff Connelly to have access to 'discovery' prior to the preliminary hearing on these charges, again indicating Defendant Potts’ and Defendant Larissa Connelly’s malicious intent.

64. Furthermore, Defendant Potts stated at the hearing that it was expected that Defendant PSP Officer McCabe would charge Plaintiff Connelly on Defendant Larissa Connelly’s harassment claims, indicating that the two were in communication before the filing of the charges on September 8, 2020 (the very day before the hearing). Plaintiff Connelly believes that Potts was lying and that she knew very well that Plaintiff Connelly had been charged.

65. The filing of the charges on the day prior to the hearing after forty-six days of McCabe’s supposed ‘investigation’ was certainly not a coincidence.

66. Notably, Potts’ ‘favorite’ message was one sent by Plaintiff Connelly to Defendant Larissa Connelly that stated (paraphrasing) that Potts was ‘an ex-ADA hack who thinks she is still trying criminal cases and has no business practicing family law’ where children’s well-being is at stake.

67. Clearly, Potts had become personally involved in Defendant Larissa Connelly’s matter and was acting on her own behalf rather than her client’s, thus subjecting Defendant Larissa Connelly to significant liability, infra.

68. The above legal proofs clearly illustrate the illegality of the September 9, 2020 proceeding and resultant order, and the criminal course of conduct of Defendants Potts, Larissa Connelly, Lombardi, and  McCabe in their conspiracy to abuse civil process and to commit fraud, via interstate wire and/or the mail, calculated to give Defendant Larissa Connelly an unfair advantage in the custody matter regarding Plaintiff OWC, and to alienate her from her Father, Plaintiff Connelly.

69. This illegal and collusive scheme was enabled by the willful and calculated violation of 231 Pa. Code § 1915.4-2, which allowed corrupt hearing officers, Defendants Christman and Lombardi, to enter wholly-baseless, and indeed void recommended orders later rubber-stamped by Defendants Platt and Sondergaard, without any accountability to the competent evidence whatsoever. Indeed, the failure to make findings of facts or conclusions of law in violation of black letter Pennsylvania law, see Connelly v. Connelly, 2341 EDA 2020 (Pa. Cmmw. Ct. Oct. 15, 2021), is proof beyond reasonable doubt of these criminals’ intent.

70. Connelly is legally trained and recognized that he had been ‘railroaded’ by Defendants Christman and Lombardi through improper coordination with Defendants Larissa Connelly, Potts, McCabe, and their criminal judicial accessories and co-conspirators. He asked his then-attorney, Defendant Paul Peters, Esquire numerous times to withdraw from the representation, but this did not occur until December 3, 2020 due to Peters’ legal professional negligence.

71. On September 24, 2020, Plaintiff Connelly served Defendant Larissa Connelly with a complaint filed in Berks County on September 9, 2020, alleging common law abuse of process and other claims. See Connelly, T. v. Connelly, L., et al., Civil Action No. 20-15787 (Berks, Pa. 2020).

72. The suit was later withdrawn by Plaintiff Connelly on the advice of Plaintiff Connelly’s then-counsel, Samuel L. Stretton, Esquire, to foster settlement communications, which were then refused by Defendant Potts.

73. On the next day, September 25, 2020, Defendant Larissa Connelly, again at Potts’ direction, filed a protection from abuse (PFA) petition against Plaintiff Connelly, based on cherry-picked messages that Plaintiff Connelly sent to Defendant Larissa Connelly advising her of the Berks County suit and threatening further litigation after Defendant Larissa Connelly cut short his phone call with Plaintiff OWC without basis, as Defendant Larissa Connelly and her mother, Defendant Janet Prewitt had been frequently doing.

74. Upon information and belief, Defendant Larissa Connelly’s PFA filing was made at Defendant Potts' urging, and Exhibit ‘A’ thereto was authored by Potts and was in retaliation for Plaintiff Connelly’s filing of the abuse of process case in Berks County.

75. Connelly had offered an apology and an 'olive branch' prior to the filing and service of Defendant Larissa Connelly’s PFA against him on September 25, 2020.

76. Furthermore, Plaintiff Connelly had prefaced his allegedly actionable remarks with a copy of the Berks County civil complaint and a letter in draft form to defense counsel in ‘.rtf’ format stating his position.

77. Connelly’s remarks subject to Defendant Larissa Connelly’s PFA action, (although admittedly crude) threatened at most litigation, not physical violence, and in  no sense placed Defendant Larissa Connelly “in reasonable fear of imminent bodily injury,” the threshold for judicial action under Pennsylvania’s Protection from Abuse laws. See 23 Pa. C.S.A. § 6102.

78. Clearly, the September 25, 2020, PFA application, much like Defendant Larissa Connelly and Defendant Potts’ other filings, was meritless and intended only to harass and abuse Plaintiff Connelly and to cause delay of his custody matter, in violation of 204 Pa. Code § 4.4 (a) (in representing a client, a lawyer shall not use means that have no substantial purpose other than to embarrass, delay, or burden a third person…”). 204 Pa. Code § 4.4 (a).

79. In filing her PFA petition against Plaintiff Connelly, Defendant Larissa Connelly, through Defendant Potts, defamed Plaintiff Connelly, having alleged that Plaintiff Connelly was an 'alcoholic' and psychiatrically impaired. These statements were false.

80. Plaintiff Connelly, who as noted is a disabled veteran of the United States Navy, honorably discharged, had undergone, pursuant to his Berks County ARD conditions, a substance abuse evaluation with the VA wherein no treatment was recommended and had a clean bill of health from his psychiatrist with the VA.

81. Moreover, Plaintiff Connelly was evaluated, at his expense, by William Morgan, Psy.D., pursuant to the baseless, illegal, and void July Custody Order, and in his report, Dr. Morgan found no indications that Plaintiff Connelly, a practicing Zen Buddhist (now Zen-Buddhist-Protestant or something), had any issues that would compromise the care or custody of Plaintiff, OWC, or that Plaintiff Connelly was a danger to anyone. Exhibit PC-*** (2021-09-06 dr morgan report).

82. Plaintiff Connelly had given Dr. Morgan a complete copy of his medical record with the Veterans Administration (“VA”), Exhibit PC-*** (mhv_CONNELLY_20240820_1906_redacted), and authorized communication with each of his medical providers for the purpose of conducting his evaluation and making his report.

83. This tort/crime/defamation rendered September 6, 2020 as the last day that Plaintiff Connelly was in physical contact with Plaintiff OWC as of the date of this writing.

84. On September 22, 2020, Defendant Potts reported Plaintiff Connelly to the West Goshen Township Chester County Police based on the same cherry-picked messages that formed the basis for Defendant Larissa Connelly’s frivolous PFA petition.

85. West Goshen Township PD Officer Kyle Maye contacted Plaintiff Connelly and advised that Plaintiff Connelly should have ‘no further contact’ with Defendant Potts.

86. Connelly assured Officer Maye that he intended no physical harm against anyone, that he would abide by the stated conditions, and the matter was concluded.

87. Defendant Potts, however, was adamant that Plaintiff Connelly should be arrested, and even requested that Officer Maye have his supervising officer review the allegations for a ‘second opinion’ on whether to charge Plaintiff Connelly. This was accomplished and Officer Maye still declined to charge Plaintiff Connelly.

88. 204 Pa. Code § 4.4 (a) states that: “(a) In representing a client, a lawyer shall not use means that have no substantial purpose other than to embarrass, delay, or burden a third person…”. 204 Pa. Code § 4.4 (a).

89. This crime/tort/defamation rendered September 6, 2020 as the last day that Plaintiff Connelly was in physical contact with Plaintiff OWC as of the date of this writing. 

90. Defendant Potts’ actions clearly indicated an extra-legal animus and an intent to embarrass Plaintiff Connelly, delay the proceedings, and place unwarranted burdens upon Plaintiff Connelly, to the point where severely injured her client by creating civil and criminal liability for her, supra and infra.

91. On September 28, 2020, Plaintiff Connelly filed a Protection from Abuse Petition (“PFA”) against Defendant Larissa Connelly alleging that Defendant Arvil Prewitt, her brother, had been ‘riding shotgun’ to intimidate Plaintiff Connelly during custody exchanges and that Plaintiff Connelly had been threatened with semi-automatic rifle fire by same during one of his drop-offs. See Connelly, T.P. v. Connelly, L.C., et al., Civil Action No. 20-16243 (Berks Co. 2020).

92. Furthermore, Plaintiff Connelly expressed concerns about the safety of the minor child, Plaintiff OWC, in Defendant Larissa Connelly’s Oxford, Pennsylvania location where firearms were/are present, and where there was a history of Defendant Arvil Prewitt (who at approximately fifty years old, still lives with his parents, Defendants Wayne and Janet Prewitt, his sister, Defendant Larissa Connelly, and, most concerning, minor plaintiff OWC) of having dealt drugs to Defendant Larissa Connelly, who herself had previously admitted to Plaintiff Connelly a history of hard drug abuse.

93. Plaintiff Connelly has been prevented from attending to this extremely dangerous situation by Defendant Larissa Connelly, her criminal attorneys, and their corrupt judicial enablers (all defendants herein), but will soon apply for termination of Larissa Connelly’s parental rights and for custody of OWC.

94. Plaintiff Connelly later withdrew his PFA petition on the advice of his then-counsel Samuel Stretton, Esquire, to, once again, foster settlement of the matters between himself and Defendant Larissa Connelly in the best interests of Plaintiff OWC, which entreaties were again refused by Defendant Potts.

95. On October 30, 2020, as Defendants Potts and Larissa Connelly had hoped, Defendant Berks County’s District Attorney, Defendant John T. Adams filed a motion to revoke Plaintiff Connelly’s ARD status based on Defendant Larissa Connelly’s harassment charges against him. See Commonwealth v. Connelly, Crim. Action No. CP-06-CR-3185-2019 (Berks Pa. 2019).

96. On November 24, 2020 Plaintiff Connelly filed an answer in opposition to Defendant Commonwealth of Pennsylvania's revocation motion describing many of the facts alleged herein.

97. On January 21, 2021, the Hon. Thomas G. Parisi, JCCP (one of the few honest, competent jurists in Defendant, Berks County), discharged Plaintiff Connelly from the ARD program as successfully completed, and not for a trial listing. See Commonwealth v. Connelly, No. CP-06-CR-3185-2019 (Berks Pa. 2019).

98. On December 16, 2020, Plaintiff Connelly filed a motion to disqualify Defendant Attorney Julie M. Potts from the OWC custody matter.

99. On January 5, 2021 Potts’ insurance company assigned attorney Defendant Paul C. Troy (Pa. Atty. No. 60875) (“Defendant Troy” or “Troy”) to Defendant Potts’ defense and he entered his appearance for Potts, filing opposition papers defending Potts’ unethical and illegal behavior.

100. On December 21, 2021, Plaintiff Connelly filed a civil contempt petition against Defendant Larissa Connelly for depriving Plaintiff Connelly of his reading time with OWC and sending OWC to daycare over his objection, and when Plaintiff Connelly was able to provide full-time care during the work week.

101. Plaintiff Connelly withdrew that petition on March 29, 2021, when Defendant Larissa Connelly obtained new counsel, Defendant Craig B. Huffman (Pa. Attorney No. 82085) (“Defendant Huffman” “Turd Ferguson” or “Huffman”), Plaintiff Connelly thereby once again hoping to put the litigation on a more conciliatory footing.

102. Soon thereafter, Plaintiff Connelly offered to attempt to settle all matters between himself and Defendant Larissa Connelly through mediation.

103. Defendant Larissa Connelly, through her new counsel, Defendant Huffman, initially complained that incorporation of a criminal prosecution into a mediation setting over which Connelly had no control would be improper.

104. Connelly agreed and offered to mediate notwithstanding the frivolous criminal charges levied against him by Defendants Larissa Connelly, Potts, and McCabe.

105. Defendant Larissa Connelly, again through Huffman, refused that offer, clearly indicating that Defendant Larissa Connelly has never been amenable to the settlement of the matters between herself and Plaintiff Connelly. Rather, she, like her attorneys, refuses to recognize Plaintiff Connelly’s right to see his daughter (and his daughter’s right to see him) and continues to this day to simply double down on her illegal and unethical conduct, causing grievous harm to Plaintiffs Connelly, OWC, and also to Plaintiffs Thomas P. Connelly, III, and EMC.

106. On May 6, 2021, Plaintiff Connelly filed a renewed contempt petition, again alleging that Defendant Larissa Connelly continued to deny the ‘reasonable phone time’ granted him by virtue of the void July Custody Order and continued to send OWC to daycare over Plaintiff Connelly’s objection. The matter was to be heard by Defendant, Chester County Master, Defendant Gregory J. Marshall (Pa. Atty. No. 47128) (“Defendant Marshall” or “Marshall”).

107. On July 17, 2021, Plaintiff Connelly wrote to Susan Shirley, Chief Court Reporter of Defendant, Chester County, requesting that a court reporter be assigned to record the pending contempt proceeding before Defendant Marshall, and arguing that the Local Rule of Court purporting to prohibit the recording of contempt proceedings (1) was nonsensical and legally inoperative for want of a subject or object of a preposition, and (2) that the Local Rule was preempted by the applicable Pennsylvania Rule of Civil Procedure.

108. An email exchange ensued, wherein Defendant Marshall  writing to Shirley stated that “if [Plaintiff Connelly] would like to challenge the [Local Rule], he would need to do so in a forum other than the hearing officer level.”

109. This absurd statement is an amazing illustration of the problem with the hearing officer system of Defendant, Chester County. Masters like Defendants Christman, Lombardi, and Marshall, all charged with performing a judicial function, are wholly incompetent to perform that function, or refuse to do so, and all with the purpose and intent of awarding their attorney ‘friends’ carte blanche, and further burdening the ‘losing’ party. Their reward is in the form of quid pro quo ‘favors.’ 

110. Plaintiff Connelly also believes that cash or its equivalents has been exchanged for these favors, which fact he intends to prove through discovery, so that he can then invite the hopefully newly competent Justice Department to prosecute these criminals.

111. At the contempt hearing wherein Plaintiff Connelly represented himself and Defendant Larissa Connelly was represented by Defendant Huffman, Defendant Marshall began by criticizing Plaintiff Connelly’s contempt application for lack of specificity.

112. This was absurd and appalling to Plaintiff Connelly because he had attached to his pleadings a detailed phone log including every call he made to Plaintiff, OWC, answered and unanswered, and noting the time of the call, from the time he had started reading to his daughter until the time of the filing of the papers.

113. Furthermore, Plaintiff Connelly had included as another exhibit a detailed, contemporaneously recorded ‘custody events log’ that provided context to and the content of many of the calls, and to Plaintiff Connelly’s allegations of contempt on the part of Defendant Larissa Connelly and Defendant Janet Prewitt, her mother.

114. Defendant Marshall claimed that the exhibits had been ‘lost’ by the family court administration, thus implicating Defendant Suzie Marker, Marshall’s supervisor, in the aforesaid conspiracy.

115. When presented with Plaintiff Connelly’s objection to the failure to schedule a court reporter, rather than hear and rule on the objection, Defendant Marshall absurdly doubled down on his ‘other forum’ excuse, stating that he was doing “what [he] has been told by his bosses and a judge for years.”

116. When Plaintiff Connelly inquired what Pennsylvania Rule of Civil Procedure authorized him to hear the matter before him (because it, hint-hint, clearly preempts the local rule), Defendant Marshall could not, or would not answer.

117. In a subsequent support hearing, Defendant Marshall demonstrated a complete lack of an awareness of the Pennsylvania Rules of Evidence or the proper conduct of a trial/hearing. EXHIBIT PC-*** (2021-07-28 transcript of hearing connelly v connelly (redacted)).

118. With their patent corruption and incompetence, the hearing officers of Defendant Chester County have destroyed any opportunity for the judicial economy that likely justified the ‘Masters’ system in the first place.

119. They are literally useless and a waste of taxpayer money, because they refuse to perform even a quasi-judicial function, and basically take the attitude, as does Defendant Marshall, that “if you don’t like it, you can get a trial de novo.” 

120. Note that as of the time of this writing, no trial judge in Chester or Delaware County has ever reviewed the merits of either of the Mothers’ claims in Plaintiff Connelly’s custody matters, after almost four years of separation of Plaintiff Connelly from his children by criminal child-abusers.

121. The hearing officers’ raison d'être is thus nothing but to impose unnecessary burdens on pro se litigants or attorneys who are not their ‘friends’ to unfairly/illegally influence the judicial proceedings.

122. Corrupt Court of Common Pleas judges, e.g., Defendants Sondergaard and Platt, are happy to maintain this system, as the attorneys benefiting therefrom support these same judges politically, ensuring their reelection and political and material homeostasis. The inter-associations of this complex conspiratorial scheme have been documented by Plaintiff Connelly and will be provided in discovery, and proved at trial (if necessary).

123. These corrupt hearing officers are wholly unaccountable because they refuse to record hearings and/or make findings of fact and conclusions of law as required by the relevant rules of civil procedure, are not subject to Defendant, Commonwealth of Pennsylvania’s Code of Judicial Conduct (though acting in a judicial capacity like Pennsylvania’s unqualified magisterial district justices), and are not disciplined by the Pennsylvania Supreme Court. See, e.g., EXHIBIT PC-*** (2021-01-28 letter to judicial conduct board).

124. Indeed, Defendants Anna C. Ciardi, Thomas J. Farrell, and others of Defendant Commonwealth of Pennsylvania’s Attorney Disciplinary Board/Counsel refuse to address the hearing officers’ misconduct, and these criminals are thus fully-enabled to carry on their illegal schemes in plain sight.

125. Plaintiff Connelly finds it appalling that Defendant, Chester County’s Court of Common Pleas has for some time thus routinely operated outside the law to deprive litigants of their due process rights and, thereby, the affection and company of their children, by conducting illegal ‘star-chamber’ proceedings in abject violation of the applicable Commonwealth regulations.

126. The scheme articulated herein is of a ‘cash-for-kids’ design, insofar as the attorneys who are ‘connected’ with the corrupt masters (and thereby to corrupt judges) can charge a premium for their services, while others, such as out-of-county attorneys, are simply ignored, as happened in Plaintiff Connelly’s matter(s). Children are treated as a commodity to be sold to the highest bidder.

127. Unlike Plaintiff Connelly (who is legally trained), most litigants do not apprehend that their rights are being abused. They feel powerless to oppose a system that requires thousands of dollars in attorneys’ fees to possibly receive a fair shake (it all depends on who you can afford). See, e.g., EXHIBIT PC-*** (Who Is Lombardi Chester County Family Court? Talk About Corrupt Custody Issues), and supra.

128. Defendant Chester County’s Court of Common Pleas is thus well-known as a judicial ‘hellhole’ and its corruption is not limited to the Family Court.

129. Plaintiff Connelly believes and avers that it is no coincidence that he was prosecuted on trumped-up charges by Defendant, Chester County’s Office of the District Attorney, whose alumni, Defendants Potts and Lombardi, as shown above, conspired and colluded together in an illegal scheme to defraud Plaintiff Connelly of his parental rights.

130. On January 25, 2021, by a copy of a letter to Defendant Commonwealth of Pennsylvania’s Judicial Conduct Board, Plaintiff Connelly requested that Defendant, Chester County’s President Judge, Defendant John L. Hall “consider adjudicating [Connelly’s] pending matters” given the “history of abusive conduct that [Plaintiff Connelly had] sustained in Chester County, and the fact of [Connelly’s] complaints against certain judges, hearing officers, and attorneys.” EXHIBIT PC-*** (2021-01-28 letter to judicial conduct board).

131. At the time, the ‘pending’ matters were Plaintiff Connelly’s custody contempt petition against Defendant Larissa Connelly and the criminal harassment charges before his predecessor, Defendant Judge Jacqueline C. Cody. Defendant Judge Hall took no action whatsoever.

132. On February 1, 2021, Plaintiff Connelly wrote to the Defendant Commonwealth of Pennsylvania’s Administrative Office of the Pennsylvania Courts (“AOPC”) requesting that an investigation of the foregoing allegations be initiated. See Exhibit PC-10 (2021-02-01 letter from connelly to AOPC).

133. Defendant Hall was copied with this correspondence. Once again, Defendant Hall took no action whatsoever. Defendant Hall is thus a disgrace to his office and must be removed from public service, and his pension revoked.

134. Defendant Hall’s negligent/criminal/tortious conduct/inaction rendered September 6, 2020 as the last day that Plaintiff Connelly was in physical contact with Plaintiff OWC as of the date of this writing.

135. Nor did Defendant Commonwealth of Pennsylvania’s criminal AOPC take any action, disclaiming any responsibility for the obvious due process violations that Plaintiff Connelly had described in his Letter.

136. Nor did Defendant Commonwealth of Pennsylvania’s then-Attorney General, Defendant Joshua D. Shapiro (Pa. Atty. No. 90101) (“Defendant Shapiro” or “Shapiro”), now Defendant, Commonwealth of Pennsylvania’s Governor, who was copied with the AOPC Letter, take any action.

137. Plaintiff Connelly believes and avers that Defendant Shapiro, in his failure to act, was/is derelict in his duty to the citizens of Defendant, Commonwealth of Pennsylvania, and that he is liable to Plaintiff Connelly and his plaintiff children for his failure to intercede in the abuse and human trafficking of those plaintiff children despite repeated notice of the same, and therefore for gross negligence under Defendant, Commonwealth of Pennsylvania’s criminal and civil law, infra.

138. Defendant Shapiro’s negligence/torts/crimes rendered September 6, 2020 as the last day that Plaintiff Connelly was in physical contact with Plaintiff OWC as of the date of this writing.

139. Plaintiff Connelly sued Defendant Shapiro and the entirety of Defendant Chester County’s bench for trafficking in minor Plaintiff OWC. See Connelly, T., et al. v. Connelly, L., et al., Civil Action No. 2022-05726-TT (Chester, Pa. 2022).

140. The matter was unlawfully dismissed by a Berks County judge appointed by the corrupt AOPC, but Plaintiff Connelly appealed, see Connelly, T.P. v. Connelly, L.C., 619 EDA 2024 (Pa. Super. 2024), and though that appeal was dismissed for failure to file a brief, ibid., Plaintiff Connelly has preserved his statutes of limitation and, more importantly, is entitled to disqualification of the entirety of Defendant Chester County’s bench in any future custody or support action with respect to Plaintiff OWC.

141. The claims herein against Defendant Delaware County’s President Judge Defendant Kevin F. Kelly (Pa. Atty. No. 43598) should obtain the same result with respect to Defendant, Delaware County’s bench, who have trafficked in Plaintiffs Thomas P. Connelly, III and EMC and are therefore incompetent to further adjudicate those custody matters (although Plaintiff Thomas P. Connelly, III has now reached majority in the four years that he has been alienated from and poisoned against Plaintiff Connelly).

142. Although it refused to act on Plaintiff Connelly’s concerns of criminal activities in Defendant Chester County in violation of that County’s certification to Defendant, Commonwealth of Pennsylvania’s Unified Judicial System to ‘follow the rules’ of civil procedure, Defendant Commonwealth of Pennsylvania’s corrupt AOPC did not hesitate to criminally, tortiously, and/or negligently interfere in Plaintiff Connelly’s Defendant, Chester County criminal matter before Defendant Cody through AOPC Attorney, Defendant Robert J. Krandel (Pa. Atty. No. 89485) (“Defendant Krandel” or “Krandel”) to protect corrupt masters, Defendants Christman and Lombardi, as will be explained in greater detail below.

143. On December 3, 2020, Plaintiff Connelly received discovery in the meritless harassment case, and on December 21, 2020, supplemental discovery, and noted the following with respect to the allegedly actionable messages received by Defendant Larissa Connelly.

144. There are no instances of name-calling and there is only one ‘curse’ word in the allegedly ‘harassing’ messages.

145. Every message communicates a different piece of information to the alleged ‘victim’, Defendant Larissa Connelly. The messages are not repetitive or crude. They are nothing more than statements of Plaintiff Connelly’s case against criminal child abuser, Defendant Larissa Connelly were she to have chosen to proceed  along a litigation path (she did).

146. If Defendant Larissa Connelly felt ‘harassed’, she could have simply blocked Plaintiff Connelly’s number. She did not. At the very least she could have interjected with a request that Plaintiff Connelly stop communicating with her. She did not.

147. Defendant PSP Officer McCabe did not contact Plaintiff Connelly as did Officer Maye in a similar situation orchestrated by Defendant Potts to further burden and harass Plaintiff Connelly (one that was ultimately resolved without resort to litigation), even though Defendant McCabe apparently falsified a police report claiming as much.

148. These facts disprove Defendant Larissa Connelly’s specious claims, channeled through Potts, that the messages were ‘harassing’ to her, or that Plaintiff Connelly had the specific intent to harass.

149. Plaintiff Connelly’s later acquittal at trial demonstrated beyond all doubt that Defendants Larissa Connelly and Potts, in soliciting the frivolous harassment charges from Defendant McCabe, simply perceived and capitalized upon an opportunity to further burden Plaintiff Connelly in his custody proceeding–to ‘put him in his place’ for daring to fight for his beloved daughter, plaintiff OWC against a conspiracy to commit fraud, racketeering and human trafficking effectuated by and through the abject violation of Defendant, Commonwealth of Pennsylvania regulations designed to prevent such corruption, supra.

150. Where a simple warning from  PSP Officer McCabe would have sufficed, none was given. Moreover, in the forty-four days between Defendant Larissa Connelly’s call to McCabe on July 27, 2020, and the filing of the charges on September 8, 2020,  McCabe conducted no investigation whatsoever into whether the allegedly actionable messages were attributable to Plaintiff Connelly. For example, no forensic evaluation was conducted of Plaintiff Connelly’s or Defendant Larissa Connelly’s cell phone.

151. More significantly, Defendant McCabe, who at the time of his ‘investigation’ had then only been a  PSP Officer for four months, claimed that on July 27, 2020, he tried to reach Plaintiff Connelly by phone “with negative results on multiple occasions,” and that he left a voicemail message for Plaintiff Connelly.

152. Upon a reasonably diligent (but not necessarily exhaustive search), Plaintiff Connelly found no records supporting Defendant McCabe’s claim that he attempted to contact Plaintiff Connelly in any manner.

153. On March 11, 2021, Plaintiff Connelly filed an omnibus pretrial motion (“omnibus motion”), EXHIBIT PC-*** (2021-03-11 omnibus pretrial motion redacted). Therein, Plaintiff Connelly stated his intent to seek McCabe’s cell phone records.

154. On April 14, 2021, Plaintiff Connelly filed a request with Defendant Commonwealth of Pennsylvania’s State Police (“PSP”) pursuant to Pennsylvania’s Right-to-Know Law (“RTKL”) for  McCabe’s cell phone records for July 27, 2020, the day he claims he attempted to contact Plaintiff Connelly.

155. On May 19, 2021, PSP wrote to Plaintiff Connelly, asserting that “it [did] not have any records in its possession, custody or control that respond to [Plaintiff Connelly’s] request.”

156. This was not surprising to Plaintiff Connelly, given PSP’s gamesmanship regarding its records. See, e.g., Judge admonishes Pa. State Police for response to request seeking email, phone records | Spotlight PA, 2022, https://bit.ly/3Nkuvxr (Accessed Sept. 8, 2024), Exhibit PC-***.

157. If Defendant McCabe was not using an official communication device, he must have been using his personal cell phone in the investigation of the harassment charges against Plaintiff Connelly. No one has cared to provide those records despite Plaintiff Connelly’s numerous requests.

158. On March 15, 2021, Plaintiff Connelly requested that then-Chester County ADA, Defendant Myles Brand Matteson (Pa. Attorney No. 323787) (“Defendant Matteson” or “Matteson”) (now a Deputy Attorney General of New Hampshire) provide Defendant McCabe’s phone records for July 27, 2020, as he surmised that Defendant McCabe was in telephone contact directly with Defendant Potts prior to charging Plaintiff Connelly, and more significantly, that he falsified the police report with respect to his statements that he contacted Plaintiff Connelly by telephone.

159. Plaintiff Connelly, in this Letter, also put Defendant Matteson on notice of his intent to bring claims against him, the Chester County Office of the District Attorney, and  Defendant Trooper McCabe should Plaintiff Connelly prevail in the criminal matter. Spoiler alert: he did, infra and supra. See, also, EXHIBIT PC-*** (2021-01-31 letter to ada dismissal demand and notice).

160. Defendant Ryan also had more than adequate notice, through her counsel, Lewis Brisbois Bisgaard & Smith LLP, of Plaintiff Connelly’s herein claims against her, but allowed the frivolous prosecution to continue anyway. See, e.g., EXHIBIT PC-*** (2021-07-21 gmail connelly, t., pet. v. hon. cody, et al. pa. 72 MM 2021 your client deborah ryan, esq.) and EXHIBIT PC-*** (2021-11-23 gmail - thomas p. connelly, jr. v. larissa c. connelly, julie m. potts, esquire and potts & shoemaker, et al.).

161. Having received no response from Defendant Matteson, Plaintiff Connelly on April 7, 2021 once again requested Defendant McCabe’s telephone records from Defendant Matteson.

162. Defendant Chester County’s Office of the District Attorney never responded with the requested phone records. Plaintiff Connelly believes and avers that this fact shows that it and Defendant Matteson were improperly coordinating with Defendants Potts and Lombardi, both alumni of that Office.

163. On March 15, 2021, Plaintiff Connelly issued subpoenas to Defendants Lombardi and Christman to appear at his trial in his criminal harassment matter and to produce therein records of ex parte communications with complaining witness, Defendant Larissa Connelly’s former attorney, Defendant Julie M. Potts.

164. Shortly thereafter, Plaintiff Connelly received a telephone call from Defendant Commonwealth of Pennsylvania’s Administrative Office of the Pennsylvania Courts (AOPC) attorney Robert J. Krandel (Pa. Atty. No. 89485) (“Defendant Krandel” or “Krandel”).

165. The purpose for the call was unclear, but Plaintiff Connelly later surmised that Defendant Krandel was attempting to coerce Plaintiff Connelly into withdrawing the subpoenas issued to Defendants Lombardi and Christman.

166. Plaintiff Connelly offered to supply Defendant Krandel with documentation specifying the purpose of the two subpoenas. Defendant Krandel refused that offer.

167. Defendant Krandel then wasted no time in filing a motion to quash the subpoenas (“AOPC motion”).

168. The AOPC motion was never sufficiently served upon Plaintiff Connelly. Rather it was served upon Plaintiff Connelly’s prior counsel, Samuel Stretton, Esquire.

169. Furthermore, the AOPC motion included a notice to plead stating that Plaintiff Connelly had twenty days to respond to the motion.

170. In the AOPC motion, at Paragraph 8, Krandel asserted that Plaintiff Connelly had “other means at his disposal to establish whatever he intends to establish in this case.” The impropriety of this statement is self-evident, and a per se violation of 204 Pa. Code § 4.4 (a).

171. On March 29, 2021, Plaintiff Connelly issued two additional subpoenas to Defendants Lombardi and Christman to attend the April 13, 2021, hearing on Plaintiff Connelly’s omnibus motion (the original subpoenas were for attendance at the trial of the matter).

172. No court notice of hearing was generated for the AOPC motion, and no further action was taken by Krandel or the trial court, Defendant Cody, until the April 13, 2021, hearing on Plaintiff Connelly’s omnibus motion.

173. However, Defendant Cody had clearly communicated ex parte with Defendant Krandel and/or material witnesses Defendants Lombardi and/or Christman because Defendant Krandel appeared at the April 13, 2021, hearing (without notice or standing), though Defendants Lombardi and Christman, whom Plaintiff Connelly had subpoenaed to that hearing, did not, clearly evidencing improper coordination/collusion/conspiracy among and between these defendants (and a violation of the judicial and attorney codes of conduct).

174. Defendant Cody began the hearing by warmly inviting Defendant Krandel to argue the AOPC motion–a motion that had not even been properly served, and to which Plaintiff Connelly had not been given an opportunity to respond, as twenty days of any imaginable service on Plaintiff Connelly had not yet elapsed. EXHIBIT PC-*** (2021-04-13 transcript of hearing 04-13-2021 comm. v. connelly).

175. When Plaintiff Connelly objected that he had not had an opportunity to respond to the motion, Defendant Cody ordered him to “be seated” rather than entertain the objection. EXHIBIT PC-*** (2021-04-13 transcript of hearing 04-13-2021 comm. v. connelly).

176. After Defendant Krandel put on his little spiel, Defendant Cody ordered Plaintiff Connelly to the podium to ‘briefly’ state his position. Plaintiff Connelly questioned this statement by Defendant Cody because Defendant Krandel had not been so cautioned, even though he had nothing of any substance to say, not having any knowledge of what Connelly was seeking in his subpoenas or why, supra. EXHIBIT PC-*** (2021-04-13 transcript of hearing 04-13-2021 comm. v. connelly).

177. Plaintiff Connelly objected to the hearing of AOPC’s motion without his having had an opportunity to respond in writing. Defendant Cody then cut Plaintiff Connelly off and ordered him to sit down and ‘be quiet’ when he attempted to argue the merits, his procedural objection having been overruled. EXHIBIT PC-*** (2021-04-13 transcript of hearing 04-13-2021 comm. v. connelly).

178. Defendant Cody then offered to reinstate Plaintiff Connelly’s right to a preliminary hearing. Plaintiff Connelly readily accepted that offer. This, however, was apparently a fraud by inducement because Defendant Cody then immediately indicated that she would deny the entirety of Plaintiff Connelly’s omnibus motion on the basis that Plaintiff Connelly had waived his preliminary hearing. EXHIBIT PC-*** (2021-04-13 transcript of hearing 04-13-2021 comm. v. connelly).

179. The hearing transcript thus evidences several per se violations of 18 U.S.C. § 1346 (honest services fraud) by Defendants Cody and Krandel.

180. Realizing that Defendant Cody had no interest in hearing Plaintiff Connelly on the merits of his application, that Defendant Cody was coordinating with Plaintiff Connelly’s adversaries, and that Defendant Cody had no idea that Pa. Rule of Evidence 408 even existed, let alone how to apply it (read the transcript, it’s hilarious, except it’s really not when you consider that Plaintiff Connelly’s liberty was put in jeopardy by these criminals), he asked to be excused. EXHIBIT PC-*** (2021-04-13 transcript of hearing 04-13-2021 comm. v. connelly).

181. Defendant Cody then threatened to hold Plaintiff Connelly in contempt of court for too forcefully placing his file folder in his bag as he was leaving. EXHIBIT PC-*** (2021-04-13 transcript of hearing 04-13-2021 comm. v. connelly).

182. On April 16, 2021, Plaintiff Connelly filed objections to Defendant Cody’s April 13, 2021 Order quashing the subpoenas and granting AOPC’s motion for a protective order, and Defendant Cody’s April 14, 2021 Order denying Plaintiff Connelly’s omnibus pretrial motion.

183. As these were simply objections, Plaintiff Connelly did not request a hearing on the matter, issued no notice to defend to the Defendant Commonwealth, nor did the Defendant Commonwealth file opposition to the objections. The objections were listed as “Pro Se Correspondence” on the Docket.

184. Nonetheless the objections were scheduled to be heard on May 24, 2021, by Defendant Cody.

185. On April 23, 2021, Plaintiff Connelly filed a motion to disqualify Defendant Cody from his criminal matter.

186. Defendant Commonwealth of Pennsylvania (through Defendant Matteson) failed to file any opposition to the motion.

187. At the May 24, 2021, ‘hearing’ of Plaintiff Connelly’s objections, Plaintiff Connelly requested a continuance due to his intent to file his application for extraordinary relief before the Supreme Court of Pennsylvania. See Commonwealth v. Connelly, Pet., Pa. 68 M.M. 2021 (Pa. 2021).

188. Defendant Cody denied the continuance request and demanded that Plaintiff Connelly present his argument. Plaintiff Connelly explained that pursuant to the applicable rules of criminal procedure, the only matter possibly pending was that of Plaintiff Connelly’s objections, and moreover that Plaintiff Connelly had not requested a hearing on them.

189. Defendant Cody insisted that Plaintiff Connelly proceed nonetheless, so he elected to proceed on his papers, as there had been no opposition filed to his omnibus motion.

190. Therein, Defendant Cody, true to form, did not forgo an opportunity to bully Plaintiff Connelly once again. At the beginning of the hearing Judge Cody insisted that then-ADA Daniel B. Yarnall, Esq., who was standing in for Defendant ADA Matteson, confer with Plaintiff Connelly about a possible plea, even after Plaintiff Connelly clearly stated on the record that he was not interested in any sort of plea of guilt.

191. Plaintiff Connelly has decided to spare Mr. Yarnall, who is not a defendant herein, because: (1) he’s now a criminal defense attorney; (2) he treated Connelly with a modicum of respect and decency; and (3) his hands were apparently tied by Defendant Ryan.

192. Mr. Yarnall will therefore, primarily because of his decency and civility, avoid civil and criminal liability for the solicitation of perjury from Defendant Larissa C. Connelly at trial, infra. The defendants would be wise to take heed, as karma operates in both directions–it is simply the universe seeking its own natural equilibrium, and Plaintiff Connelly is merely its agent.

193. Upon Plaintiff Connelly’s parting, Defendant Cody asserted that she could have issued a bench warrant for Plaintiff Connelly’s alleged ‘failure to appear’ at the immediately prior trial listing on May 11, 2021. Connelly explained to Defendant Cody that he had contacted Chester County Pretrial Services and was told that he did not have to appear, but silently noted Cody’s failed attempt to dominate him.

194. On or about June 14, 2021, Plaintiff Connelly filed a praecipe for determination of his motion to disqualify Judge Cody filed April 23, 2021, and his motion to compel production of  McCabe’s phone records filed May 7, 2021.

195. In each application, Plaintiff Connelly had requested an evidentiary/argument hearing and had directed the applications, in his praecipe, to Defendant John L. Hall, JCCP.

196. Defendant, Chester County’s Clerk of Court Yolanda Van De Krol and/or Court Administrator Patricia Norwood-Foden failed to list the motions for a hearing.

197. This omission likely constituted a violation of 18 U.S.C. § 1346 (honest services fraud), and a predicate act under 18 U.S.C. §§ 1961-68 (RICO). Plaintiffs reserve all rights to the imputation of liability to Yolanda Van De Krol and/or Patricia Norwood-Foden pending further discovery in this matter.

198. On or about May 25, 2021, Plaintiff Connelly filed an application with Defendant, Commonwealth of Pennsylvania’s Supreme Court for extraordinary relief, Commonwealth v. Connelly, Pet., Pa. 68 M.M. 2021 (Pa. 2021), requesting that the Court dismiss the criminal charges against Plaintiff Connelly. Although the application for extraordinary relief was granted, relief was denied per curiam and without opinion.

199. On June 17, 2021, Defendant Cody entered an order denying Plaintiff Connelly’s motion to disqualify (which was noticed to and should have been heard by Defendant Judge Hall), and an order denying Plaintiff Connelly’s “Objections, Request for Disclosures and Request for Recusal.”

200. As to the order denying Plaintiff Connelly’s motion to disqualify, Judge Cody, as the subject of that motion, was not competent to decide it (it was not a recusal request but a disqualification motion). Furthermore, Plaintiff Connelly’s praecipe for determination clearly requested that Defendant Judge Hall hear the application.

201. Moreover, despite Plaintiff Connelly’s request, he was denied an opportunity to be heard at an argument/evidentiary hearing on the disqualification issue, which appears to be Defendant Cody’s (and Hall’s) modus operandi. This was a clear violation of Plaintiff Connelly’s due process rights under the constitutions of Defendant, Commonwealth of Pennsylvania and of the United States.

202. As to the order denying Plaintiff Connelly’s “Objections, Request for Disclosures and Request for Recusal,” the denial of “any relief requested by [Plaintiff Connelly] in [his] filing,” without giving him an opportunity to be heard, not only implies that there were issues to adjudicate, but in the same breath, dismisses those issues summarily, resulting in yet another due process violation, and another count of honest services fraud, a 18 U.S.C. §§ 1961-68 (RICO) predicate act, supra and infra.

203. On June 17, 2021, Defendant Cody entered an order denying Plaintiff Connelly’s unopposed motion to compel, without scheduling a hearing or offering an opinion.

204. On July 27, 2021, Defendant Nathan M. Schenker (Pa. Atty. No. 40211) (“Defendant Schenker” or “Schenker”), Defendant Chester County’s Public Defender, filed a motion to be relieved as standby counsel.

205. In filing that motion, Defendant Schenker violated client confidences by attaching a private letter sent to him by Plaintiff Connelly. See 204 Pa. Code § 1.6.

206. In the attached letter, Plaintiff Connelly called out Schenker’s failure to make himself available, directly or through his subordinate attorneys, to Plaintiff Connelly for “consultation and advice” pursuant to 234 Pa. Code Ch. 1, Rule 121 (D).

207. Instead of addressing the merits of Plaintiff Connelly’s concerns, Defendant Schenker ridiculed Plaintiff Connelly before Defendant Cody, prejudicing him thereby, by quoting Plaintiff Connelly’s concern that Schenker’s office was colluding with Defendant Cody and Plaintiff Connelly’s adversaries.

208. As noted above, improper collusion among judges, attorneys and hearing officers appears to be an epidemic in Defendant, Chester County.

209. A news article written by sycophant ‘reporter’ Michael Rellahan makes it clear that Defendant Schenker was/is more concerned with cooperating with “prosecutors, probation officers, court administrators, and, ultimately,  county officials” than the zealous advocacy on his clients’ behalf pursuant to his duty under Pa. R. Prof'l. Cond. 1.3. See "Schenker Named Chester County’s Chief Public Defender – Daily Local". Dailylocal.com, 2022, https://bit.ly/3JFmmS8 (consulted September 6, 2024).

210. The article shows that Plaintiff Connelly’s suspicions of improper relationships between stand-by counsel and the trial court were spot-on.

211. Defendant Schenker’s aforesaid acts and omissions constituted a violation of 18 U.S.C. § 1346 (honest services fraud) (a predicate act under 18 U.S.C. §§ 1961-68 (RICO)), obstruction of justice, and legal professional negligence.

212. Defendant Schenker’s motion was of course granted by Defendant Cody on July 27, 2021, before Plaintiff Connelly was even made aware of its existence, in further violation of Plaintiff Connelly’s due process rights, and establishing yet another count of honest services fraud.

213. As the above facts prove (and as it is generally known amongst members of the bar), Defendant Chester County is a criminal enterprise fueled (and ruled) by corruption, sycophancy and quid pro quo–one that routinely denies its litigants due process of law by simply ignoring the relevant rules of criminal and civil procedure, and the due process rights afforded by the state and federal constitutions.

214. Defendant Judge Hall was/is derelict in his duty to supervise, despite adequate notice, the actions of his subordinate judges, Defendants Cody, Sondergaard and Platt, the lattermost of whom violated the Judicial Conduct Code by giving character evidence for Defendant Lombardi in her 1925 (b) opinion within Plaintiff Connelly’s appeal, see Connelly v. Connelly, 2341 EDA 2020 (Pa. Cmmw. Ct. Oct. 15, 2021)), and, e.g., EXHIBIT PC-*** (2021-01-28 letter to judicial conduct board), and for permitting the Chester County judicial system to operate outside the relevant rules of civil procedure for years, to the prejudice of innumerable litigants and their children.

215. Justice in Defendant Chester County is truly a joke. But it’s not funny, because every day families are destroyed, and children are abused. These criminals must be prosecuted and incarcerated. If the federal authorities won’t act, Plaintiff Connelly will.

216. As the ‘captain of the ship’ Defendant Judge Hall is responsible for the liability that has accrued to the plaintiffs through the negligent/tortious/criminal acts and omissions of the judges and hearing officers supposedly under his ‘supervision.’

217. As noted in Plaintiff Connelly’s petition for extraordinary relief, Commonwealth v. Connelly, Pet., Pa. 68 M.M. 2021 (Pa. 2021), no conviction could have been sustained against Plaintiff Connelly given Defendant Cody’s egregious conduct denying Plaintiff Connelly due process, and for the reasons stated in that petition and Plaintiff Connelly’s omnibus pretrial motion, the most compelling of which was that since Defendant PSP Officer McCabe conducted no forensic examination of Plaintiff Connelly’s or Defendant Larissa Connelly’s cell phone, there was no way to attribute the allegedly harassing messages to Plaintiff Connelly.

218. Given the foregoing, Defendant Deborah Ryan, then District Attorney of Defendant Chester County, was grossly derelict in her duties with respect to Plaintiff Connelly’s matters, and indeed abused her office, and must be removed from public service immediately, as will be explained in more detail below.

219. “As an officer of the court and instrument of the criminal justice system, the prosecutor's duty is to seek justice, not simply convictions." Commonwealth v. Clancy, 192 A.3d 44, 59 (Pa. 2018).

220. A district attorney "represents the Commonwealth…and seeks justice only, equal and impartial justice, and it is as much the duty of the district attorney to see that no innocent [person] suffers as it is to see that no guilty [person] escapes,” and she should therefore “act impartially.” Commonwealth v. Toth, 314 A.2d 275, 278 (Pa. 1974).

221. Here, Defendant Ryan, much like Defendant Berks County District Attorney John T. Adams, infra, conspired to maintain a frivolous prosecution against Plaintiff Connelly despite having no path to a (legal) conviction, proving that she is unable to fulfill her sworn duties as a judge of the Chester County Court of Common Pleas, and like Adams, she must be prosecuted and/or impeached.

222. Furthermore, as Plaintiff Connelly has shown in his application for extraordinary relief in Commonwealth v. Connelly, Pet., Pa. 68 M.M. 2021 (Pa. 2021), the prosecution against him lacked probable cause. See, e.g., Curley v. Auto. Fin. Co., 343 Pa. 280 (1941).

223. “A prosecutor in a criminal case shall refrain from prosecuting a charge that the prosecutor knows is not supported by probable cause.” Pa. R. Prof'l. Cond. 3.8.

224. In Plaintiff Connelly’s experience, when positions of power are abused, as here, there is rarely an opposition on the merits. That has been the theme of Plaintiff Connelly’s matters in Defendants Delaware, Chester, Berks, and Lebanon Counties, infra.

225. Defendant Commonwealth of Pennsylvania failed to answer any of Plaintiff Connelly’s applications before Defendant Cody, which was both evidence of collusion with the trial court and a violation of Defendant Ryan’s duty to act impartially. See Commonwealth v. Toth, 314 A.2d 275, 278 (Pa. 1974).

226. At the time, Defendant Ryan had been styling herself an advocate for children. See, e.g., Deb Ryan, Chester County DA Deb Ryan: Protecting children from abuse is the responsibility of every adult, Daily Local (2022),  (last visited Oct 5, 2024), Exhibit PC-***.

227. However, Ryan’s participation with her then-office’s alumni, Defendants Potts and Lombardi, in a scheme to defraud Plaintiff Connelly of physical custody of his beloved daughter, plaintiff OWC, proves that Defendant Ryan is a hypocrite and a fraud, and that her interest in the welfare of children is limited to her own political benefit. See, e.g., EXHIBIT PC-*** (2021-01-31 letter to ada dismissal demand and notice).

228. As noted, parental alienation is recognized as child abuse in Pennsylvania. See, e.g., EXHIBIT PC-*** (Cases of Parental Alienation in Pennsylvania Courts).

229. Defendant Ryan has therefore participated in the state-sponsored and supported abuse of Plaintiff Connelly’s children, proving that she is ethically and morally incapable of executing the duties of her judicial office, and should be immediately removed from public service, and her pension revoked. She, like the rest of her political chums in Chester County, is nothing more than a criminal, serial, child-abuser. See, e.g., EXHIBIT PC-*** (2021-01-31 letter to ada dismissal demand and notice).

230. Despite the aforesaid liability that Defendant Larissa Connelly’s counsel have created for her, Plaintiff Connelly, as he has done at every opportunity, offered to settle all of his matters with her, including the instant matter.

231. Defendant Larissa Connelly, through Defendant Huffman, once again refused to accept Plaintiff Connelly’s generous offer, and resorted to her original plan of attempting to assassinate Plaintiff Connelly’s character through spurious and unfounded allegations.

232. On December 3, 2021, Defendant Larissa Connelly through Defendant Defendant Huffman filed an ‘Opposition to Certificate of Trial Readiness’ and a ‘Pretrial Statement,’ both of which baselessly continued the attempted character assassination of Plaintiff Connelly. Both of these pleadings are actionable.

233. First, in her opposition to the certificate of trial readiness through Defendant Huffman, Defendant Larissa Connelly stated that the parties’ Chester County custody matter was not ready for trial because “Connelly [had] not complied with the psychological evaluation that was order [sic] by the Court and [Defendant Larissa Connelly] intends to file a request for a custody evaluation.”

234. These arguments were specious, frivolous, and intended only to further burden and prejudice Connelly, and to delay the trial of Plaintiff OWC’s custody matter, having been based on an order (July Custody Order) that was (arguably) identified as void by the Pennsylvania Commonwealth Court. See Connelly v. Connelly, 2341 EDA 2020 (Pa. Cmmw. Ct. Oct. 15, 2021).

235. As noted, Plaintiff Connelly substantially complied with the void July Custody Order by obtaining an independent psychological evaluation at his own cost.

236. Dr. Morgan’s report was based on a thorough review of Plaintiff Connelly’s entire medical record with the Defendant Veterans Administration (“VA”), and interviews with Plaintiff Connelly’s treatment providers, and there was no indication of any issue that would affect Plaintiff Connelly’s ability to properly care for his children.

237. There was no factual or legal basis for Plaintiff Connelly to be required to undergo a psychological or substance abuse evaluation, and certainly not to undergo additional evaluations based on lies and illegal orders.

238. Furthermore, Defendant Larissa Connelly, and Defendant Attorneys Potts and Huffman had seventeen months to file a contempt petition with the court if they truly believed that Connelly had not substantially complied with the void July Custody Order. They did not. This was because Plaintiff Connelly was in substantial compliance and they knew it, and their frivolous and unfounded claims and allegations were intended only to vex and burden his pursuit of reasonable visitation with Plaintiff OWC.

239. Defendant Larissa Connelly’s attempts, through Defendant Huffman to leverage an illegal and void order are frankly disgusting, given that Defendant Huffman’s firm, Defendant Eckell, Sparks, et al., represented Defendant Larissa Connelly on appeal, and had notice of the Commonwealth Court’s findings before the filing of the Certificate of Trial Readiness and Pretrial Statement on behalf of Defendant Connelly.

240. Huffman also filed a frivolous petition for allocatur on Defendant Connelly’s behalf.

241. The only remotely legal basis for the granting of allocatur was that “the lower court ha[d] erroneously entered an order quashing or dismissing an appeal,” 210 Pa. Code § 1114 (7), an argument that Defendant Larissa Connelly could not ethically make because she had already certified, through Defendant Huffman’s firm, Defendant Eckell Sparks, et al., that the quashal of Plaintiff Connelly’s appeal was proper. See Defendant Larissa Connelly’s “Application for Reargument, En Banc,” Connelly v. Connelly, 2341 EDA 2020 (Pa. Cmmw. Ct. Oct. 15, 2021) filed October 22, 2021 at p. 2 (“[Larissa Connelly] agrees that the [July and September Chesco Custody Orders] are not final and the quashal was appropriate…”).

242. The frivolous allocatur petition was of course denied, and was clearly intended only to delay the custody trial regarding OWC, and to harm and further prejudice Plaintiff Connelly, and alienate him from OWC.

243. Defendant Larissa Connelly’s Pretrial Statement filed through Defendant Huffman, was similarly actionable.

244. As Plaintiff Connelly stated on his blog, https://bringonorahome.com (currently unpublished but available via wayback), when one doesn’t have the facts or law on her side, she must cheat in order to win. This has been Defendant Larissa Connelly and her attorneys’ modus operandi over the last four years.

245. Defendant Larissa Connelly was even willing to perjure herself in her testimony against Plaintiff Connelly in Plaintiff Connelly’s criminal trial before Defendant Cody, falsely denying that she has ever used hard drugs, and falsely denying that Defendant Arvil Prewitt, her brother, who lives with OWC, dealt her illegal drugs.

246. Plaintiff Connelly will be subpoenaing Kristen Keech, an ‘on-air talent’ and Defendant Larissa Connelly’s former ‘best friend forever’ (“BFF”), and Defendant Arvil Prewitt, her brother, to the jury trial herein to establish that Defendant Larissa Connelly perjured herself.

247. However, that was certainly not the first time that Defendant Larissa Connelly lied to gain an unfair advantage in her custody case. Plaintiff Connelly filed private criminal complaints against Defendants Larissa Connelly and Julie Potts for conspiracy to provide false information, and for providing false information, to a law enforcement officer (Defendant McCabe). As was expected, then Chesco DA Defendant Ryan refused to prosecute these claims against her ‘victim’ Defendant Larissa Connelly, and her ‘buddy’, Defendant Julie Potts.

248. Upon information and belief, Defendant Potts and her firm were contributors to Defendant Ryan’s campaign for District Attorney (along with Defendant Judge Alita Rovito, who conspired with Defendant Ryan to derail the OWC custody trial, infra). This is how ‘justice’ is served in corrupt Defendant Chester County, Pennsylvania–a la carte. Defendant Ryan also has/had improperly collusive relationships with Congresswoman Chrissy Houlahan and Defendant Analisa Sondergaard (investigation ongoing).

249. Defendant Larissa Connelly, through Defendant Huffman, further claimed in her papers that Plaintiff Connelly “declined to exercise his supervised physical time with the child since the entry of the Court’s second order.”

250. This statement was only partially true. As noted above, due to Defendant Larissa Connelly’s levying of frivolous criminal charges against Plaintiff Connelly filed the day before the illegal Lombardi hearing that resulted in the also illegal and void September Custody Order, Plaintiff Connelly lost his job, and due to multiple frivolous criminal prosecutions in Defendants Chester and Berks Counties, supra and infra, was unable to find W-2 employment with anyone (due to the pendency of criminal charges).

251. After more than four years of separation, Plaintiff Connelly, a father first-and-foremost, is simply dying to see Plaintiff OWC, if only just to give her a hug, but he, until now, has not been able to afford the substantial fees associated with the supervised custody illegally and unlawfully imposed upon him by defendant criminal masters and judges of Defendant, Commonwealth of Pennsylvania. See, e.g., Exhibit PC-*** (2024-08-21 application for IFP status).

252. Plaintiff Connelly was never “declining to exercise” his custody time. He simply could not/cannot afford it due to Defendant Larissa Connelly’s disruption of his life through her illegal and unethical acts taken in coordination with and on the advice of her criminal, unethical attorneys, and with the cooperation of corrupt judicial and bully PSP officers, and corrupt judicial and executive branch officers in defendant Chester, Berks, Delaware and Lebanon Counties.

253. It was thus simply abject evil on Defendant Larissa Connelly and Defendant Huffman’s part to cite to supervised custody that was unlawfully imposed by a provably corrupt master (Defendant Lombardi), and rendered a non-starter due to Defendant Larissa Connelly’s frivolous harassment charges and tortious interference with Plaintiff Connelly’s employment contracts.

254. Defendant Larissa Connelly, through Defendant Huffman, further claimed that throughout the course of their relationship “[Plaintiff] Connelly had become increasingly mentally unhinged.”

255. This statement was absolutely false, defamatory, and scandalous, and meant only to harass, burden, and unfairly prejudice Plaintiff Connelly, and to delay the custody trial in the custody matter regarding OWC.

256. Connelly intends to depose Defendants Joseph Kayati and Lorena Montecalvo in this matter. They were in close association with Plaintiff Connelly, Defendant Larissa Connelly and OWC from late 2015 until the parties’ separation in August of 2019.

257. Defendants Kayati and Montecalvo, domestic partners, will testify that for the entire aforementioned period, Plaintiff Connelly never acted “irrationally, vindictively” or unpredictably, or was ever “mentally unhinged.”

258. These parties will further testify that they had never seen Plaintiff Connelly consume alcohol during that entire period.

259. That is because at his and Defendant Larissa Connelly’s wedding in 2015, Plaintiff Connelly took Zen Buddhist vows including the promise to not consume intoxicating liquids. Plaintiff Connelly interprets this aspirational vow as the only alcohol that he may consume is brewed by himself or is shared with him. Plaintiff Connelly explained this to Dr. Morgan, although he didn’t mention it in his report.

260. Although Plaintiff Connelly admitted to Dr. Morgan that he has had periods of excessive drinking in his life upon the deterioration of his marriages/relationships, Dr. Morgan opined that Plaintiff Connelly had “recovered” from any prior (undiagnosed) alcohol problems, and that he was “not seen as an angry person” by his treatment providers.

261. Plaintiff Connelly’s medical records and the SoberLink reports thus fully supported Dr. Morgan’s expert opinion, which was that Plaintiff Connelly “is a caring individual who loves his daughter and wants to do what is necessary to be a good Father.” Exhibit PC-*** (2021-09-06 dr morgan report).

262. Defendant Larissa Connelly and Plaintiff Connelly had been separated since August of 2019. Therefore, Defendant Larissa Connelly’s defamatory statements claiming that Plaintiff Connelly was an alcohol abuser were not only false but also stale, and would have been subject to a motion in limine charging irrelevance and unfair prejudice pursuant to 225 Pa. Code §§ 401 and 403 in the trial of the custody matter, had the custody trial not been derailed by corrupt Chester County Judge and former ‘master,’ Defendant Alita Rovito, infra.

263. Concerning the relevant period, Plaintiff Connelly has numerous witnesses, including but not limited to Defendants Joseph Kayati and Lori Montecalvo, Kyle Donaldson, John Atkins, Elizabeth Germano, and Emma Dean, that would have testified (had Connelly felt that he would have had a fair trial, or that allowing his children’s abusers to further abuse them by putting them on the stand was in any way an acceptable solution to his legal problems) that Plaintiff Connelly has never put his children in danger in any way, shape, or form, by abusing substances, through mental health issues, or otherwise.

264. Indeed, Plaintiff Connelly’s abandonment of his custody claims for almost five seemingly interminable years of abject pain and suffering, is per se evidence that he, unlike his children's criminal, abusive co-parents, always puts his children first.

265. These witnesses would have also testified, had the trial not been derailed by the criminal acts of Defendant Rovito, infra, that Plaintiff Connelly was at all times an outstanding parent to OWC and her siblings, and that Defendant Larissa Connelly was a terrible partner to Plaintiff Connelly and an egregiously sub-par parent to OWC, which fact is also borne out by her herein-described criminally abusive conduct.

266. Defendant Larissa Connelly, through Defendant Huffman, further claimed that “in addition to underlying medical illness likely caused by “childhood trauma  [Plaintiff Connelly] has organic brain issues that have resulted in him having a shunt put into his brain.”

267. Again, Huffman resorted to false allegations that he, as a non-medical professional, was not competent to make.

268. First, the statement that Plaintiff Connelly has an underlying illness caused by “childhood trauma” was absolutely false. There is no such indication in any of Plaintiff Connelly’s medical records, which of course Defendant Huffman never had.

269. Therefore, this false and reckless statement was clearly intended only to further delay, burden, and prejudice Plaintiff Connelly, and to further delay the inevitable reunification with his daughter, OWC.

270. Also, Defendant Huffman, not having qualified himself as a medical expert in the custody matter, and not having seen Plaintiff Connelly’s medical records, had no competent basis for this statement, which requires expert opinion. This tactic is reminiscent of Defendant Attorney Potts incompetent and defamatory statements at the Lombardi hearing, supra.

271. Similarly, Defendant Larissa Connelly’s statement through hack Defendant Attorney Huffman that Plaintiff Connelly has “organic brain issues,” and the implication that same had the potential to affect Plaintiff Connelly’s parenting abilities was similarly false, defamatory, scandalous and incompetent as irrelevant, unfairly prejudicial, lacking proper foundation and constituting the speculative opinion of a lay person.

272. These torts/crimes/defamations rendered September 6, 2020 as the last day that Plaintiff Connelly was in physical contact with Plaintiff OWC as of the date of this writing. 

273. “Organic brain syndrome, also known as organic brain disease, organic brain disorder, organic mental syndrome, or organic mental disorder, refers to any syndrome or disorder of mental function whose cause is alleged to be known as organic (physiologic) rather than purely of the mind.” Organic brain syndrome, Wikipedia, https://bit.ly/31N0aVp (consulted September 6, 2024) (emphasis added).

274. Plaintiff Connelly has never been diagnosed with any species of organic brain syndrome, due to his VP shunt or otherwise. He has been diagnosed with chronic PTSD, stemming from assaults by police in 2019 and 2022, supra and infra, and the criminal alienation from his children and unlawful incarceration by the defendants herein, supra and infra. However, this mental condition is not of organic origin.

275. Moreover, Dr. Morgan in his report noted that Plaintiff Connelly’s former treating psychologist/therapist, Dr. Caffrey “[was] not aware of any impact on Mr. Connelly cognitively or emotionally as a result of his brain surgery.”

276. Plaintiff Connelly was on active duty with the U.S. Navy and working with the South African Navy in 1995 when he apparently contracted meningitis, causing hydrocephalus (water on the brain).

277. The meningitis also triggered a sudden and permanent lactose intolerance and irritable bowel syndrome (“IBS”).

278. Plaintiff Connelly’s iron will carried him through almost four years of Navy flight training from primary flight training (in the T-34 Turbo Mentor) to selection for the tactical jet program (flying the T-45 Goshawk) while suffering headaches from the undiagnosed moderate hydrocephalus and diarrhea from the undiagnosed lactose intolerance and IBS. It is that same will that has carried him through four plus years of alienation from his beloved children.

279. After being refused a medical waiver for a second tympanostomy that was rendered necessary due to barotrauma experienced during flight, and the Navy Flight Surgeon’s refusal to send him for an MRI, Plaintiff Connelly left the jet program and ultimately the Navy.

280. In 1999, as soon as Plaintiff Connelly had medical insurance, he consulted a neurologist who diagnosed him with hydrocephalus secondary to the 1995 meningitis infection, and a ventriculoperitoneal (VP) shunt was placed in early 2000 at the Hospital of the University of Pennsylvania (“HUP”).

281. In October of 2016, while married to Defendant Larissa Connelly since 2015, Plaintiff Connelly was in Reading, Berks County at a criminal hearing on behalf of a client, two and one-half hours away from the parties’ then-home in Woodbury, New Jersey, when he noticed spinal fluid leaking out of his head.

282. The VP shunt had failed, and Plaintiff Connelly was hospitalized, again at HUP, to have the shunt replaced, this time with an adjustable model.

283. Connelly’s recovery was difficult, requiring multiple visits to HUP Neurosurgery to adjust the shunt in mitigation of Plaintiff Connelly’s almost constant headaches.

284. Connelly did fall into a depression during this time, and sought psychiatric treatment at VAMC Philadelphia.

285. The depression was not related to any diagnosed organic brain disease, but likely to the difficult recovery from surgery, and the fact that Defendant Larissa Connelly refused to work or to support Plaintiff Connelly in any way through this difficult time, even refusing to touch him.

286. Plaintiff Connelly was forced to remain the family’s sole source of income, as he was then operating a solo legal practice (even filing motions and pleadings from his hospital bed), and with very little help from Defendant Larissa Connelly in any way, the burden on Plaintiff Connelly was intense and heavy.

287. Plaintiff Connelly therefore sought and obtained a contract position with GlaxoSmithKline (“GSK”) as a digital analytics project manager, an entirely different field, and one for which Plaintiff Connelly was required to self-train to accomplish the transition from a then twelve-year legal career, which he was happy to leave because of the disgusting conduct of attorneys and judges, e.g., supra and infra, to one in technology.

288. Connelly thereafter started a consulting business with a friend (and likely witness herein) Kyle Donaldson, and during much of 2019, was working two full-time jobs: for GSK, and for Penske in Reading through the partners’ consulting firm, Enactum, LLC.

289. During this period, Plaintiff Connelly lived with Mr. Donaldson’s family in the Reading area during the workweek, because the commute from Penske to the home he then shared with Defendant Larissa Connelly and OWC in Woodbury, New Jersey was two-and-one-half hours.

290. Kyle Donaldson will testify that Plaintiff Connelly read to Plaintiff OWC to sleep via Facebook Messenger video chat every night without fail (until Defendants Potts and Lombardi’s criminal acts stopped it cold), e.g., Exhibit PC-*** (❤️4myKids), and that Plaintiff Connelly spent time interacting positively with Kyle’s children, even helping with their math homework on occasion.

291. After an initial offer on a house closer to Reading fell through, Plaintiff Connelly began renting a room, feeling guilty about the imposition on Kyle and his family.

292. In June of 2019, Plaintiff Connelly was at Defendant Little Oley Tavern, having walked there from his room to do homework for his second bachelor’s degree in Mathematics, when he was assaulted by four bar patrons after putting his arm around a woman he had met there, and defended himself. The four men or, more than likely, one of the three police officers that arrived at the scene, broke Plaintiff Connelly’s ankle in three places, causing permanent, irreparable damage, supra.

293. Connelly and Defendant Larissa Connelly considered themselves separated at the time. The August, 2019 separation date results from Plaintiff Connelly and Plaintiff Connelly having attempted a reconciliation and having been intimate at that time.

294. Ultimately, Defendant Larissa Connelly quit the couples counseling paid for by Plaintiff Connelly after lackluster participation, because she “never liked it.”

295. Defendant Larissa Connelly, through Defendant Huffman, claimed that “Connelly’s alcohol abuse led to him getting injured and arrested in a fight…some time [sic] after the parties’ separation.”

296. This was another reckless, unprovable assertion designed simply to improperly attack Plaintiff Connelly’s character with impertinent material.

297. The ‘bar fight’ criminal case, like every other case that Plaintiff Connelly was a party to since 2019 (save his acquittal on the harassment charges, now also expunged) was never litigated on the merits, so there are no findings of fact or conclusions of law.

298. This pattern follows that of the OWC custody case, where two illegal pseudo-final orders were entered without any hearing on the merits whatsoever. See Connelly v. Connelly, 2341 EDA 2020 (Pa. Cmmw. Ct. Oct. 15, 2021).

299. The ‘bar fight’ criminal case terminated in a dismissal of Plaintiff Connelly’s charges upon his successful completion of ARD (despite the best efforts of Defendant Berks DA Adams and his defendant minions to unlawfully interfere), Plaintiff Connelly was acquitted of the frivolous harassment charges filed by Defendants Connelly and Potts and prosecuted by Defendant Ryan, pled no contest to two summary harassment counts, and guilty to one harassment count in the three frivolous prosecutions improperly brought by Defendants Edward and Jennifer Brooks, PSP Defendant Green, and Defendant Disciplinary Counsel Mark Gilson, and prosecuted by Adams and his co-conspirator subordinates, infra, all resulting in a ‘criminal record’ (after approximately twenty criminal charges, felonies and misdemeanors since 2019, and six months of pretrial detention), of three ‘tickets’ and court costs, nothing more, supra and infra.

300. Moreover, Dr. Morgan in his report noted that Plaintiff Connelly’s claims that he was likely drugged in the ‘bar fight’ incident were credible. See Exhibit PC-*** (2021-09-06 dr morgan report).

301. Defendant Larissa Connelly and her counsel were copied numerous times with Dr. Morgan’s report, so their above statements regarding the proximate cause of the ‘bar fight’ were reckless, unprovable, scandalous and impertinent, and were clearly made for an improper purpose.

302. Moreover, like all of Defendant Larissa Connelly’s false and defamatory allegations against Plaintiff Connelly, this allegation (really an opinion) did not appear in her subsequently filed, wholly conclusory custody complaint.

303. If Defendant Larissa Connelly really had concerns about Plaintiff Connelly’s parenting ability, she could have, and should have, brought such allegations in her custody complaint, thus illuminating further that her post-complaint allegations were meritless, brought for an improper purpose, and that she was willing to lie to abuse OWC through alienation of Plaintiff Connelly.

304. Defendant Larissa Connelly’s behavior of record thus depicts a sick, mentally-disordered individual who cannot be trusted with the care of the parties’ child, Plaintiff OWC. See, e.g., What Are The DSM-5 Diagnostic Criteria For Narcissistic Personality Disorder (NPD)?" medscape.com (2022), https://wb.md/3IjNTaq (consulted September 6, 2024).

305. Defendant Larissa Connelly’s conduct and the conduct of her attorneys was evil, disgusting, illegal, and irrational, and constitutes evidence per se that Defendant Larissa Connelly is not fit to parent Plaintiff OWC. Her parental rights must be terminated.

306. Furthermore, Defendant Larissa Connelly’s aforesaid defamatory statements through Defendant Huffman represent clear violations 204 Pa. Code § 3.3 (a)(1), which prohibits a lawyer’s making “a false statement of material fact or law to a tribunal,” 204 Pa. Code § 3.3 (a)(1), and 204 Pa. Code § 4.4 (a), which prohibits a lawyer’s using means “that have no substantial purpose other than to embarrass, delay, or burden a third person…” 204 Pa. Code § 4.4 (a).

307. Even though Defendant Larissa Connelly’s allegations were false, she and her unethical attorneys expected to prevail because they were engaged in a conspiracy with Defendants Lombardi, Christman, McCabe, and corrupt judges of Defendants Chester County and Commonwealth of Pennsylvania’s Court of Common Pleas and other judicial and executive branch personnel calculated to defraud, vex and burden Plaintiff Connelly through the imposition of illegal and void orders, all in violation of Plaintiff Connelly’s right to due process and equal protection of law (as a male, disabled veteran, and later an indigent), and designed to punish Plaintiff Connelly and to alienate him from Plaintiffs OWC, Thomas P. Connelly, III and EMC.

308. Plaintiff Connelly has called out the disgusting conduct of these selfish, narcissistic, morally and ethically corrupt criminals, and is now in a position to gain primary custody of OWC through termination of Defendant Larissa Connelly’s parental rights.

309. Defendant Larissa Connelly continues to have no choice but to double down on her lies, because that is, and has always been her entire ‘case’ against Plaintiff Connelly. She was/is willing to lie and abuse Plaintiff OWC to protect her false self-image as a good parent. In reality, she is a criminal, serial child abuser, as are her attorneys and co-conspirators named herein and in the companion state and federal matters.

310. Defendant Larissa Connelly through Defendant Huffman even claimed that Plaintiff Connelly’s first-filed federal action, Connelly, et al. v. Connelly, et al., Civil Action No. 5:21-cv-3981-JMG (E.D. Pa. Aug. 31, 2021), justified continued supervised visitation by Plaintiff Connelly with OWC, due to its indication of a “paranoid manner of thinking” in Plaintiff Connelly.

311. This statement is laughable and moreover appears to be a projection on Defendant Huffman’s part. Unlike Defendant Larissa Connelly’s allegations,  Plaintiff Connelly’s claims against the parties in this action and its companion cases are based on legally-actionable, provable facts, not false, defamatory, impertinent and scandalous accusations, supra.

312. If anyone’s conduct indicates a disordered mental state it is Defendant Larissa Connelly’s. She, despite repeated offers from Plaintiff Connelly to work things out, and an ever-shrinking legal and moral authority for her behavior, continually doubled-down on her garbage, manufactured ‘case’ against  Plaintiff Connelly through unethical, and quite frankly, unskilled, hack attorneys, who did/do nothing but create liability for Defendant Connelly and their co-conspirators in Defendant Commonwealth of Pennsylvania’s judiciary and executive.

313. Such is also indicated by Defendant Larissa Connelly’s pretrial “Witness List.” Therein, she had the audacity, through Defendant Huffman, to threaten to call Plaintiff Connelly’s “estranged” children, Plaintiffs Thomas P. Connelly, III, and EMC to their sister’s custody trial.

314. Plaintiff Connelly’s children are “estranged” from Plaintiff Connelly due to the herein-described conspiracy amongst and between Defendant Larissa Connelly, Defendant Dora L. Kassel (misspelled as “Cassel” in ’s Pretrial Statement), and their respective defendant attorneys and judicial and executive branch enablers, leveraging a corrupt and broken system to alienate and then poison Plaintiff Connelly’s children against him.

315. However, the prospect of having to cross-examine his plaintiff children in court was in and of itself a sufficient basis for Plaintiff Connelly to decline to prosecute his custody claims with respect to OWC, but there were certainly others, as will be explained in greater detail below.

316. As noted, the two mothers (Defendants Larissa Connelly and Dora Kassel) even coordinated several times to bring Plaintiff Connelly’s children together for visits behind his back, causing him great emotional pain and anguish.

317. Defendant Kassel was listed as a witness on Defendant Larissa Connelly’s pretrial paperwork, even though she and Plaintiff Connelly cooperated in parenting Thomas P. Connelly, III and EMC for ten years, without a court order and without incident, until Defendant Larissa Connelly’s former counsel, Defendant Potts, began her campaign of character assassination against Plaintiff Connelly in July 2020.

318. This is per se evidence of improper coordination between Defendant Larissa Connelly, the Kassel Defendants, and their respective attorneys and judicial and executive branch enablers.

319. Defendant Larissa Connelly and her criminal co-conspirators must not be permitted to benefit from their malfeasance in alienating Plaintiff Connelly from his ex-spouse, Defendant Dora Kassel, and his three plaintiff children, thereby allowing those children to be poisoned against him in Plaintiff Connelly’s absence, all in an effort to gain an unfair tactical advantage over Plaintiff Connelly with respect to his children’s custody.

320. Defendant Larissa Connelly and her numerous criminal co-conspirators have inflicted tremendous emotional pain upon Plaintiff Connelly, leveraging a corrupt system enabled, supported and groomed by Defendant Commonwealth of Pennsylvania, to court-nap Plaintiffs Thomas P. Connelly, III, EMC, and OWC. In doing so, they have caused damage that will take years of counseling to repair in its survivors.

321. Both Mothers, Defendant Larissa Connelly and Defendant Dora Kassel, have thereby clearly abused OWC, Thomas P. Connelly, III, and EMC and have unfairly and illegally usurped Plaintiff Connelly’s ability to bond with them for four years. 

322. Defendant Larissa Connelly and Defendant Dora Kassel have, until today, destroyed Plaintiff Connelly’s ability to earn enough money to properly defend himself against their lies and attempted character assassination. They are morally bankrupt cheaters, liars, narcissists, criminals and child-abusers.

323. Defendant Defendant Huffman’s aforesaid specious claims on behalf of Defendant Larissa Connelly smack of desperation. Huffman should be worried--he has navigated his client into a terrible position, as on his and Defendant Potts’ advice, Defendant Larissa Connelly has abused Plaintiff Connelly’s children, and has thereby proved by evidence of record in the Chester County trial court that she is an unfit parent, paving the way for the termination of her and, in Delaware County, Defendant Dora Kassel’s parental rights.

324. As noted above, on November 1, 2021, Plaintiff Connelly represented himself at his trial on the frivolous harassment charges, and was acquitted by Defendant Cody, after Defendant Ryan dismissed two counts to avoid a jury trial, that she knew Plaintiff Connelly, an effective trial attorney, would win.

325. During the pendency of the meritless Chester County criminal harassment case, Plaintiff Connelly was excluded from every holiday, every birthday, and all in-person and even virtual contact with his children, and because of superseding frivolous prosecutions in Berks County, infra, has continued to have no contact with his children for almost five years.

326. This state supported and enabled abuse of Plaintiff Connelly and his children is intolerable, and Plaintiff Connelly and his plaintiff minor children deserve to be made whole, and to see the offending parties punished.

327. The time for justice has arrived, and Plaintiff Connelly will not stop until those responsible for the criminal abuse of his children have been imprisoned. If the federal authorities will not act, he will do it himself through qui tam and private criminal prosecutions.